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94th Congress 
2d Session 










NOVEMBER 1976 > 

Printed for the use of the 
Committee on Interior and Insular Affairs 

79-767 O 



House of Representatives 

JAMES A. HALEY, Florida, Chairman 

ROY A. TAYLOR, North Carolina 
HAROLD T. JOHNSON, California 
PATSY T. MINK, Hawaii 
LLOYD MEEDS, Washington 
JOSEPH P. VIGORITO, Pennsylvania 
RON DE LUGO, Virgin Islands 
PAUL E. TSONGAS, Massachusetts 
BOB CARR, Michigan 
GEORGE MILLER, California 

JAMES J. FLORIO, New Jersey 

JOE SKUBITZ, Kansas, Ranking Minority 

DON H. CLAUSEN, California 
PHILIP E. RUPPE, Michigan 
MANUEL LUJAN, Jr., New Mexico 
DON YOUNG, Alaska 
SHIRLEY N. PETTIS, California 

Charles Conklin, Staff Director 
Lee McElvain, General Counsel 
Henry R. Myers, Special Consultant on Nuclear Energy Matters 
Michael C. Marden, Minority Counsel 

Subcommittee on Energy and the Environment 
MORRIS K. UDALL, Arizona, Chairman 

MANUEL LUJAN, Jr., New Mexico 

BOB CARR, Michigan 
RON DE LUGO, Virgin Islands 
GEORGE MILLER, California 
PAUL E. TSONGAS, Massachusetts 
JOSEPH P. VIGORITO, Pennsylvania 

Stanley E. Scoville, Staff Counsel 
Michael B. Metz, Minority Staff Counsel 

Note. — The first listed minority member is counterpart to the subcommittee chairman. 


Members of the Committee on Interior 

and Insular Affairs 
U.S. House of Representatives 
Washington, D.C. 20515 

Dear Colleagues: 

As part of its nuclear oversight responsibility, the 
Committee's Subcommittee on Energy and the Environment 
has been concerned with health hazards associated 
with nuclear radiation. 

The Subcommittee chairman has sent to me a transcript 
of a House Environmental Study Conference meeting at 
which disparate views were presented with regard to 
hazards arising from the presence of artificial radia- 
tion sources. Since this is a subject of widespread 
interest, I am making the transcript available to all 
Members of the Committee. 










November 3, 1976 

SHIRLEY N. rrrris. c» 

The Honorable 
James A. Haley, Chairman 
Committee on Interior 
and Insular Affairs 
U.S. House of Representatives 
Washington, D.C. 20515 

Dear Mr. Chairman: 

Transmitted herewith is the transcript of a symposium 
organized by the House Environmental Study Conference for 
the purpose of discussing the effects upon people of "low 
level" ionizing radiation. People are exposed to such 
radiation from both artificial and natural sources. Of 
considerable concern is the extent to which radiation 
produced by artificial sources is a hazard to human health. 
This question has been a matter of public debate for more 
than three decades. As the transcript makes clear, experts 
remain in substantial disagreement with regard to the 
nature of these risks. 

Meetings such as those organized by the Environmental 
Study Conference help to delineate the areas of agreement 
and to indicate those aspects of the problem which deserve 
additional research. While the Subcommittee on Energy and 
the Environment was not involved in the organization of the 
conference (and views presented therein do not necessarily 
reflect views of Subcommittee members) I am forwarding the 
meeting record because I believe it will be exceedingly useful 
to both experts in the field and to non-experts who wish to 
obtain a sense of the controversy. 

Subcommittee on Energy and 
the Environment 



Introduction vii 

I. Opening Statements by Sen. Gary Hart and Dr. 

Karl Morgan 1 

II. Low-Level Radiation, What Is It and VJhat Are 

Its Major Sources? 7 

III. Health Effects of Low-Level Radiation, What Are 

They and When Do They Appear? 9 

IV. Dose-Response Relationships, Linear or Non-Linear? . . 20 

V. Protection of Special Groups 35 

VI. Federal and State Responsibilities in Regulation, 

Monitoring and Inspection 49 

VII. Current Radiation Protection Standards, Responsibility, 

and Scientific Basis 75 

VIII. Health Effects of Radiation, Is the Data Base 

Adequate for the Determination of Standards? What 
Research Is Needed? 84 

IX. Health Effects to Occupational and General Populations 

Exposed to the Present Federal Standards 95 

X. The Cost-Benefit Theory of Federal Radiation Standards, 

Is It a Proper System? What Are Alternative Systems? 101 

XI. Specific Recommendations for Congressional Hearings, 

Legislation or Other Actions 109 


Selected Bibliography on Effects of Low Dose Radiation 
on Man 113 

Glossary of Radiation Health Terms 125 

Addition to the Testimony of Dr. Victor E. Archer, M.D. 

from a Letter to Mr. Bruce Myles, April 1 , 1976 129 



Addition to the Testimony of Dr. Edward S. Martell, 
Unresolved Health Effects of Internal Alpha Emitters . . . .130 

Recommendations Made to the Environmental Study Conference, 
Submitted to the Record by Dr. Rosalie Bertell 133 

Letter Submitted to the Record by Dr. Bernard Cohen 135 



On May 4, 1976, a panel including scientists and public 
health officials presented a wide spectrum of views on the health 
effects of low-level ionizing radiation during a one-day conference 
aimed at informing Congressional Members and their staffs on this 

The conference was organized by the Environmental Study 
Conference, at that time composed of a bipartisan group of 165 
House Members, and the Environmental Policy institute, a non- 
profit research center. The purpose of the meeting was to provide 
insights into a question increasingly asked by the public: how 
harmful to health, if at all, is the low-level ionizing radiation 
from the nuclear fuel cycle, medical x-rays, and other artifical 

Members of the House and Senate co-sponsoring this confer- 
ence included Representatives Richard Ottinger, Gilbert Gude, 
James Jeffords, and John Seiberling, and Senators Gary Hart, 
Abraham Ribicoff, Edv/ard Brooke, and Jacob Javits. 

The following pages contain a transcript of the meeting, 
edited and reorganized by the Congressional Research Service. 

Digitized by the Internet Archive 
in 2013 

MAY 4, 1976 

Washington, D. C. 

The Conference met, pursuant to notice, at 9:35 a.m, in room 
1202, Dirksen Senate Office Building, Hon. Gary Hart presiding. 

Present: Senator Hart (presiding). 

Senator Hart. Ladies and gentlemen, I think we are prepared 
to proceed with this discussion this morning. I am sorry that my 
friend Dick Ottinger, Congressman from New York, will not be able 
to be with us for the opening of today's conference. However, it 
is my understanding that he will be in and out throughout the day, 
hopefully rather frequently. It was primarily through the coor- 
dination of the Environmental Study Conference, which Congressman 
Ottinger chairs, that this forum was originally organized. 

The conference today is the first Congressional effort in 
several years to review the health effects of low-level ionizing 
radiation from nuclear power facilities, medical and dental x-rays 
and other sources. 

The purpose of the conference is to provide a Congressional 
forum for the discussion of recent research findings which indi- 
cate the need for closer scrutiny of Federal programs designed 
to protect the public from radiation exposure. 

The conference is co-sponsored by the Environmental Study 
Conference, a group of about 165 members of the House, Representa- 
tives Ottinger, Gude, Jeffords, and Seiberling, and Senators 
Ribicoff, Brooke, Javits and myself. 

Our speakers represent a wide range of views on the health 
effects of low-level radiation and the extent to which the pub- 
lic and occupational subgroups are and will be protected from 
low- level radiation. 

The questions surrounding low-level ionizing radiation are 
becoming increasingly salient as pressures mount for this nation 

to turn to nuclear power as an answer to our energy shortage. As 
this industry expands, many more citizens will be exposed to high- 
er levels of radiation. 

As we know, humanity has always been exposed to naturally oc- 
curring background radiation. Dr. Gofman, the co-discoverer of 
Plutonium, has estimated that this naturally occurring radiation 
causes approximately 19,000 extra cancer deaths annually, and be- 
tween 58,000 and 580,000 genetic deaths per year in this country 

With these figures in mind, it seems almost unbelievable that 
government policies could advocate the existence of artificially 
produced radiation, with its consequent cost to human life. How- 
ever, this has happened, and the average American is exposed to 
almost twice the radiation that occurs naturally. 

We can do little about background radiation, but we can, and 
must, curb that radiation produced by man. Current regulations 
permit exposures of 170mrem annually. A disturbing consequence 
of every individual receiving this dose could amount to about 
32,000 extra cancer and leukemia deaths every year, according to 
Drs. Gofman and Tamplin. 

As if this exposure were not enough, employees of nuclear in- 
dustries are, in my mind, incredulously exempted from those regu- 
lations. They can legally receive radiation at levels thirty 
times that of the general population -- an exposure which has been 
calculated to increase the risk of leukemia and cancer by 5 per- 
cent every year, and to significantly lower life expectancy. 

Our investigations today, however, should not limit itself 
to the more glamourous issue of radiation from nuclear industries, 
which amounts to only a small percentage of the total threat to 
human health. Radiation from medical and dental x-rays accounts 
for an estimated 3,000 deaths per year from various forms of can- 
cer and genetic damage, according to the International Commission 
on Radiological Protection. The Commission also estimates that we 
may be introducing approximately 30,000 extra deaths into future 
generations each year from genetic effects. The National Academy 
of Science, the BEIR Committee, and the Medical X-ray Advisory 
Committee all agree that radiation from diagnostic x-rays can be 
significantly and easily reduced. 

Federal regulations are intended to define the quantity of 
exposure that the human body can safely accumulate. But since 
any accumulation produces biological damage, these standards are 
ultimately based on an arbitrary bureaucratic decision about how 
many adverse health effects, a euphemism for deaths, we will put 
up with -- the so-called "acceptable costs." 

The hard questions are not being asked. My colleagues and I 
have asked all of you to participate in this forum to address and 
hopefully shed new light on these very important questions. 

What are involved here are not mere statistics, but people 
-- individual human lives. And it is ultimately these people, and 
we as their elected representatives, who must make these hard 


decisions. We must be sure that these decisions are based on the 
facts, with full knowledge of the possible consequences. It is 
the facts which must be aired in forums like this, and not con- 
fined to the obscure publications of myriad Federal agencies. 

I am confident, and I am sure my colleague. Congressman 
Ottinger is confident, that this conference will mark an impor- 
tant stage in the dialogue that must take place as pressures for 
nuclear acceptance mount. 

As for the time-table this morning, we will be meeting from 
9:30 until just after 12:00 o'clock, taking a break for lunch and 
continuing at 1:45 until approxiamtely 4:30, or until we have ex- 
hausted the subjects at hand. 

Chairing the conference will be Dr. Karl Morgan, Professor of 
Health Physics at the Georgia Institute of Technology, one of the 
pioneers in radiation protection. 

I am now pleased to let Dr, Morgan introduce our panelists 
and further explain the format. 

Dr. Morgan. Good morning. 

The panel consists of persons who are well-known in this 
field and many of us have formulated opinions through the years. 
I am thinking that perhaps I need a larger gavel here to cut 
some of us off if we really get tangled up close in some of these 

Beginning on my left, Mr. Taylor, I do not believe is here. 
George Taylor is scheduled to be with us. He is the executive 
secretary of AFL-CIO. 

Dr. Frank Collins, consultant on occupational safety for 
the Oil, Chemical and Atomic Workers on my left. 

Dr. John T. Edsall, Professor Emeritus of Biology at Harvard 
University, and Chairman of the VI International Conference of 

Dr. Irwin Bross has been director of the biostatistics at 
Roswell Park Memorial Institute for Cancer Research in Buffalo, 
New York, for over 17 years. 

Dr. Rosalie Bertell, research associate at the Roswell Park 
Memoral Institute. 

Dr. Victor Archer, who is medical director of the U.S. Pub- 
lic Health Services, National Institute for Occupational Safety 
and Health, Salt Lake City, Utah. 

Mr. Seymour Jablon, currently associate director with the 
Medical Follow-up Agency of the National Research Council, Nation- 
al Academy of Sciences and staff officer for the Radiation Effects 
Research Foundation. He also served previously as Chief of the 
Department of Epidemiology and Statistics of the Atomic Bomb Casu- 
alty Commission and is a consultant to the BEIR Report Advisory 


Dr. Edward Martell , now with the National Center for Atmos- 
pheric Research, Boulder, Colorado and formerly attached to the 
Strategic Air Command as an advisor on high altitude fall-out. 

Dr. Victor Bond, associate director in life sciences at 
Brookhaven National Laboratory, Upton, New York since 1967 and 
formerly a member of the BEIR Report Advisory Committee. 

Dr. Ernest Sternglass, Professor of Radiology at the Univer- 
sity of Pittsburgh. 

Leo Goodman is a consultant in atomic energy safety. He has 
not arrived yet. (He arrived later.) 

Dr. Charles Richmond is associate director of biomedical and 
environmental sciences, Oak Ridge National Laboratory, Tennessee. 

Dr. William Ellett, Criteria and Standards Division of the 
Environmental Protection Agency, Office of Radiation Programs. 

Dr. Bernard Shleien, Office of Medical Affairs of the Bureau 
of Radiological Health, Food and Drug Administration. He pre- 
viously spent 16 years with the Public Health Service's radiation 

Dr. Mark Barnett, associate director of the Bureau of Radio- 
logical Health's Division of Training and Medical Applications. 

Dr. Roger Mattson, director of NRC's Division of Siting, 
Health and Safeguards Standards. 

Dr. Helen Caldicott, a pediatrician who for several years was 
director of cystic fibrosis research at Adelaide Children's Hos- 
pital, Adelaide, Australia and who is currently conducting clini- 
cal research in cystic fibrosis at the Boston Clinic. 

Dr. Bernard Cohen, director of the University of Pittsburgh's 
Nuclear Physics Laboratory was not able to be with us. (Material 
has been included in the Appendix.) 

I do not see Dr. John Gofman. He is Professor Emeritus of 
Biomedical Physics, University of California at Berkeley, and 
Chairman of the Committee for Nuclear Responsibility. (Sickness 
prevented his attendance. Material has been included in the Ap- 
pendix. ) 

These are the panelists. Several have not yet arrived. 
Hopefully they will be with us shortly. 

I would now like to explain the procedures we are proposing 
to follow. The purpose of this conference is to address the ques- 
tion of low-levels of exposure to ionizing radiation, sources of 
this exposure, measures to reduce and control this exposure, the 
biological consequences of this exposure, the radiation protection 
standards and their adequacy and research programs designed to 
answer some of these questions. 

The staff of the Environmental Study Confernece, of which 
Congressman Ottinger is Chairman, has prepared a list of 17 


questions which address this subject, and I am sure in answering 
these questions, we will raise some new ones and that we will not 
be expected to solve all of the issues or to provide answers to 
the questions which will completely satisfy all of the proponents 
and opponents of nuclear energy. 

I hope, however. Senator Hart, we will clarify some of the 
issues and enable members of Congress and their staff to better 
understand the problems and what action, if any, should be taken 
to bring about appropriate corrections. 

We have a very tight schedule, and in order to stay on sche- 
dule and finish by 5:00 o'clock this afternoon, I have been asked 
to rigidly limit the time of each speaker to three minutes response 
to any question, with the exception of question number 5, where we 
will allow 5 minutes for each speaker. 

I will read each question as we come to it, and call upon 
members of the panel to respond in the order of their names as now 
listed on our provisional agenda. Please stay within these time 
limits, and at the close of the morning session and at the after- 
noon session there will be fifteen minute periods for questions and 
comments from the floor, and especially from members of Congress 
and their staffs. And those of you in the audience, when you have 
questions or responses, please state your name so that it can be 
recorded on the record. 

Mr. Myles has handed me a paper in which it has been requested 
that a few definitions be given. While some of the audience is 
assembling, maybe I can attempt a few quick definitions. 

First of all LET, the linear energy transfer, in simple terms 
(not as a college professor defines it), relates to the density of 
ionization, to the number of ion pairs along the track, a linear 
path, or a straight portion of the path of an ionizing particle. 
To those of you with physics background, it is essentially the same 
as stopping power or it relates to specific ionization. 

It defines how thick the track of ions is. In the case of 
alpha particles, as an example, in one centimeter of air, you 
would probably have about ten thousand ion pairs along that track, 
whereas for a beta particle or an electron you would have something 
like a hundred ion pairs per centimeter of air. 

For that reason the alpha particles, if they are given off in 
living tissue, are much more harmful than the lower LET radiation 
from beta and gamma radiation. 

Then there was a question of what are daughter products. It 
so happens for many of the radioactive materials, when they decay 
radioactively , they decay into another radioactive daughter, may- 
be a succession of daughters which are radioactive, decaying on 
down until eventually you arrive at a stable product where the 
half-life is very long. 

Then there is the question about ionizing and nonionizing 
radiation and why exclude nonionizing radiation from our discus- 
sion. When I was approached to chair this meeting, that question 
came to me immediately because it so happened, and I believe it is 


true, that the risk of nonionizing radiation may be as great, if 
not greater in some respects than those of ionizing radiation. 

When we speak of ionizing radiation, we mean those radiations 
that can tear loose the electrons from the atom with which they 
are associated leaving a plus and minus charge, i.e. the positive 
ion and the negative electron. 

In the case of nonionizing radiation, you are talking about 
some type of radiation that does not have enough energy per unit, 
particle or photon, to bring about the separation of the electrons 
from the atom. There you are speaking of something like visible 
light, ultraviolet, microwave radiation, RF radiation, mechanical 
radiation such as sonic, ultrasonic and infrasonic radiation. 


Chapter II 

Low-Level Radiation, What Is It and What Are 
I ts Major Sources? 

Dr. Morgan. We come now to the first question which has been 
prepared by the staff, namely. What is low-level ionizing radia- 
tion and what are the major sources about which we should be con- 

I will attempt an answer to this question to lead off this 

There is no agreed upon definition of low-level ionizing 
radiation exposure. Rather than list all of the definitions and 
take a weighted average, or be indecisive, I am going to be arbi- 
trary and perhaps a bit dictatorial and define low-level radia- 
tion exposure in the case of the radiation worker as that which is 
likely to result in a dose that is equal to or less than the max- 
imum permissible occupational dose values as recommended by the 
National Council on Radiation Protection and Measurements and as 
summarized in the NRCP Report No. 39, 1971. 

Thus, low-level dose for the radiation worker will be taken 
as the dose which is equal to or less than 75 rems per year to 
the hands, 30 rems per year to the forearms, 5 rems per year to 
the whole body, gonads, lenses of the eye and red bone marrow, 
15 rems per year to all other body organs. 

With this as the boundary conditions of occupational expo- 
sure, and one-tenth of these values as limits for non-occupa- 
tional exposure and 170 millirem per year as the maximum average 
for the population as a whole, we can, in the discussion that 
follows indicate whether or not these levels are satisfactory or 
whether they should be changed. 

I would like to express the opinion at the outset that these 
levels are satisfactory only so long as they are considered as 
upper limits that we strive not to reach, and when we operate un- 
der the philosophy that we must avoid unnecessary exposure and 
keep both occupational and non-occupational exposures as low as 
practicable and as low as readily achievable. 

The second part of the question is What are the major sources 
of low-level exposure? 

The answer is given in the BEIR report as of 1972 for the 
average whole body exposure in the U.S. and the values are much 
the same today, namely, natural background, about 100 millirem per 
year; medical and dental, 73 millirem per year-, fall-out, 4 milli- 
rem per year; occupational, about 0.8: nuclear power, 0.003 milli- 
rem per year; and nuclear power extrapolated into the year 2,000, 
less than 1 millirem per year. 

Do any of the panelists which to add to this definition of 
low-level exposure? (There was no response.) 


Now, we will take this as the boundary condition of our de- 
finition. By boundary, I mean low-level is defined as these val- 
ues or any values less than these values, from zero up to these 


Chapter III 

Health Effects of Low-Level Radiation, 
What Are They and When Do They Appear? 

Dr. Morgan. We come to the second question that has been 
suggested. We have not indicated names of those on the panel who 
would like to respond, but I welcome you to do so. I will start 
out with an attempted answer to the question -- What are the 
health effects, known and suspected, of low-level ionizing radia- 
tion? When do these effects show up? 

My answer would be, present medical techniques are not suf- 
ficiently sensitive to detect any immediate effects of these low- 
level exposures. The consequence of low-level exposure is that 
the person has a greater risk than otherwise of having a malig- 
nancy, depending on the age of the person, sex, magnitude of dose, 
type of radiation, body organ radiated, kind of malignancy and so 
forth. The malignancy may manifest itself in one to two years, 
or after, say 50 to 80 years, and in the vast majority of cases, 
a cancer resulting from radiation exposure is indistinguishable 
from one originating from other causes. 

Some scientists believe that exposure to ionizing radiation 
results in aging or life-shortening due to non-specific effects 
and have suggested that life-shortening may be on the order of 
10"^ life spans per rem. This would, in the case of a 70-year 
human, correspond to Ih days life-shortening per rem exposure of 
the total body. 

I think from this we recognize that epidemiological studies 
of very large populations exposed to these low-levels of radia- 
tion for many years would have to be conducted in order to demon- 
strate effects of low-level exposure. For example, on the BEIR 
hypothesis, a thousand persons exposed to 5 rem per year, to the 
total body, for thirty years, would be expected to result in only 
an increase of about 15 cancers above normal and an average life- 
shortening -- if there is a non-specific life-shortening -- of 
each person of a little more than one year. 

Would some panelists like to respond to this? 

Dr. Bertell. I would just like to point out some of the 
results hidden behind the hypothesis of life-shortening, which 
I think is now a viable and testable hypothesis. 

Life-shortening means that the person is vulnerable to the 
diseases of aging at an earlier point. So I would like to in- 
clude in our consideration of radiation effects such things as 
diabetes mellitus, cardiovascular disease, stroke, hypertension 
and even suicide, cataracts, a whole slew of things which we nor- 
mally connect with aging. 

Dr. Morgan. Thank you very much. Are there other comments? 
Yes, Dr. Bross. 

Dr. Bross. I would like to respond. I think the figures are 


79-767 O - 76 - 2 

somewhat obsolete. I think that the actual effects are substan- 
tially larger. What has happened is, as we do more research we 
find larger effects. 

Years ago, Alice Stewa rti/ had found a 50 percent to 100 per- 
cent increase in leukemia in the children whose mothers had x-rays 
of the fetus during pregnancy. We found 50 percent when we first 
analyzed the Tri-state survey which is the basic source of data 
that we have been using. While this was large enough to confirm 
the earlier reports, it did not convince the radiologists who had 
not been previously convinced. However in 1970, the Department 
of Biostatistics at Roswell, looked more closely at children who 
were defined by their medical histories as "susceptibles . "1/ The 
diseases in this included asthma, hives, eczema, allergy, pneu- 
monia, dysentery and rheumatic fever. 

In the susceptible children, we found a 500 percent increase 
instead of a 50 percent increase. In our latest analyses, using 
a procedure which is still more sensitive and gets down to the 
persons who are actually affected by the radiation, we get a 5000 
percent increase in leukemia. 

What I think is that the previous analyses of the data have 
not brought out the problem clearly. This whole matter needs to 
be reconsidered. 

I think the scientific evidence of cumulative genetic degra- 
dation we are prepared to produce will indicate the need for sub- 
stantial reduction in the currently permissible exposure levels. 

Dr. Morgan. Thank you. Dr. Bross. Other comments? Dr. 

Dr. Caldicott. I would just like to mention the genetic 
effect on future generations. We can extrapolate from animal 
experiments, but we know the human species is the most sensitive 
species to radiation. We have already had radiation around, ar- 
tificial radiation, for about 50 years. We know that background 
radiation during the centuries has produced us because of survi- 
val of the fittest, in that the mutations which have been good 
have survived, the bad mutations have died. We know that the 
majority of mutations occurring now are deleterious or bad, and 
produce disease. We do not know the effects of low-level radia- 
tion on the gonads, the testes and ovaries where the new gener- 
ations are to be produced, because it will take many generations 
to assess this damage, and by then it will be too late. 

There are two forms of mutations or damage to genes and eggs 
and sperm. One is dominant, which would be seen in the next 
generation. One is recessive, and may be carried by people 
through generation to generation, such as cystic fibrosis where 
one in twenty of us carry this gene. This disease is a common 
fatal disease of childhood. We all carry hundreds of such dele- 
terious recessive mutations. 

Much is unknown about the long term effect of radiation on 
human beings. Time will provide the evidence, i.e., hundreds of 
years; we will have to wait and see. 


Dr. Morgan. Are there other comments? Mr. Jablon? 

Mr. Jablon. I would just like to comment on some of the re- 
marks that have been made. 

The largest study that I know of involves essentially an un- 
selected population, the studies of the survivors of Hiroshima 
and Nagasaki. We have, of course, paid a great deal of attention 
to the problem of trying to identify specific effects of rather 
large doses, not small . 

There has not been to date, and the studies have now been 
going for thirty years, any evidence of cardiovascular disease 
being affected by the acute doses. 

The chronic effects have largely been in the area of cancer 
production . 

Dr. Morgan. Dr. Bertell? 

Dr. Bertell. I would like to respond to Mr. Jablon on the 
Hiroshima data. I have looked at that quite carefully. What he 
said was correct, but this is a sensitive point. He referred to 
acute doses of radiation, which I believe are at least over 200 
rad. I am interested, and I think this conference is interested, 
in low-level effects; diabetes mellitus and cardiovascular disease 
were significant at the lower levels. 

There is a built-in assumption in the study on the Hiroshima 
data, anything that shows up at a low level should show up worse 
at a higher level. I think this is false to the biological pic- 

You are dealing here, as far as I can see, with an overkill. 
If the cells are destroyed, they are sloughed off from the body. 
They do not continue to live within the body and produce misin- 
formation and reproduce themselves within the body. 

The effects at the low levels are different from the effects 
at the higher level. We cannot say, because something was not 
more acute at a high level, therefore it did not occur as a radia- 
tion related thing. 

Mr. Jablon. May I respond to that? 

Dr. Morgan. Dr. Martell has asked for the floor. 

Dr. Martell. In the context of the last comment, you might 
let him go ahead. 

Mr. Jablon. I would like to respond in two ways. First, I 
would like to refer back to something Dr. Morgan said in his ini- 
tial statement. 

Dr. Morgan stated that the effects of low-level radiation 
were certain things. I am sure he would agree that this is infer- 
ential. Nobody, in fact, has ever demonstrated that cancers do 
occur at the kind of low levels we are talking about today. 


It seems reasonable to believe that we can extrapolate from 
effects observed at high levels to what might be found at low 

I see that Sister Bertel 1 is shaking her head; no doubt she 
will have something to say about that. 

In any case, to assume, then, that an effect on the cardio- 
vascular system will occur at low levels of radiation when it is 
not observed to occur at high levels depends on something other 
than human data to substantiate it, and we can all have our own 
opinions about what is at work here. 

Dr. Morgan. Dr. Bertell? 

Dr. Bertell. There are three fuzzy ideas that go around 
about radiation, first that all exposure is harmful, secondly, 
that genetic damage is observable but it cannot be connected 
specifically with certain diseases, and thirdly that there is a 
nonspecific generalized effect similar to aging. This is the 
kind of vague hypothesis which I tried to address by measuring 
what I call the aging effect, because I do not know what else to 
call it, but apparently within the human body we have a biofeed- 
back system or have certain chemicals which enable us to respond 
to change in our environment. 

As we grow older, our responses are less perfect, or we are 
less able to take care of some kinds of homeostatic adjustments. 
From the measurements which I did in the Tri -state study, you can 
find a comparable effect from radiation. 

In other words, I am talking about something that happens 
to you when you are exposed to radiation and which is comparable 
to what happens to you when you live over the period of a year 
exposed to natural background radiation or whatever else you are 
exposed to. 

I think what we are dealing with here is not a question of 
exposing the whole population and noting that a few people get 
cancer. What we are dealing with is the fact that everybody gets 
an effect. You have some kind of an insult on the human body 
that is measurable, and this happens to everybody, all groups. 

Your risk of cancer, leukemia, of perhaps many other things 
is increased, and that is where the chance element comes in, but 
it is a secondary effect. 

Some of this is clear and can be proven. It indicates a 
need for further research and research along this line, because 
if we do not ask the right questions, no matter now long we study 
and look at the data, we are not going to get the answers out of 

What I am proposing here is not that all of the questions 
are answered, but that there is a new technology available. It 
is viable, promising, has already given some results, and needs 
to be broadened. 

We need to apply this to the data available. We need to ask 
better questions. 


Dr. Morgan. Dr. Sternglass? 

Dr. Sternglass. There is very serious concern that what we 
have just heard about the possibility of a generalized aging ef- 
fect that would affect heart disease has in fact happened during 
the period of nuclear testing. I would like to show that on one 
slide in just a minute. (See Figure 1.) 

This is a plot of the disease called arteriosclerotic heart 
disease, identified by the International Disease Classification 
Number 420, for the period 1945 to about 1970. 

It shows the mortality rate per 100,000 for the states of 
New Mexico, Utah, Georgia, Texas and Illinois. 

As you can see, also from the data for the U.S. average, 
there was a very sharp and unexplained rise starting about '48 
when this classification of disease was introduced. It sharply 
rose and peaked just exactly at the time of the end of nuclear 

You can see from the dots marked U.S. 410-13 that it has come 
down very rapidly since then. This is now supported by animal 
studies that show that animals given high doses of radiation and 
cholesterol together develop a high incidence of arteriosclerotic 
heart disease. 

I suggest it is this kind of synergistic effect between rad- 
iation and cholesterol that is totally unexpected which is some- 
thing that we must absolutely look into. 

The same increase and decline in heart disease we have now 
seen in Europe and we have in England and Wales, in proportion to 
the amount of strontium 90 deposited from north to south, just as 
for New Mexico, Utah, and Georgia where we find there is an in- 
creasing amount of rainfall and a proportionate increasing amount 
of strontium 90 in the milk. 

Until we have fully resolved this kind of a possibility, that 
arteriosclerotic heart disease may be produced by a combination of 
dietary chemicals and radiation, I think to go ahead with the 
major reliance on nuclear energy with associated emissions of nu- 
clear plants could be a disaster for our nation. 

Dr. Morgan. Dr. Archer? 

Dr. Archer. About the figures that Dr. Sternglass was show- 
ing us; it occurred to me that this sort of situation can result 
when the composition of the population is changing. A lower birth- 
rate could well appear on some of the mortality charts. That in- 
creases death rate and things. 

Dr. Sternglass. I will comment on that. 

We examine this by age group as well. Each age group shows 
it independently. Furthermore cancer in Japan and heart disease 
in the U.S. has come down sharply again in recent years, and the 
same kind of pattern occurred in countries with very different 











Mortality Rote for 
Heart Diseose 


W (410-13) 

.t ♦ ♦ 



I .... I ■ ... I .... I .... 1 ... I . ■ . . I 

1940 '45 '50 '55 '60 '65 '70 '75 

Figure 1 

economic and social economic factors. It is a worldwide pheno- 
menon, the sudden rise and sudden declines in arteriosclerotic 
heart disease associated with the onset and decline of nuclear 

I do not mean by any means to claim that this proves beyond 
a shadow of a doubt what I am saying. We are dealing with un- 
known amounts of alpha emitters that may be getting into the ar- 
teries. We know from animal studies and recent human studies of 
women who had been exposed to post-operative radiation treatment 
for breast tumors, that a number have developed arterial compli- 

This has been published in Radiology (Consequences to Radi- 
ologists and Medical Specialists), recently. We know that radia- 
tion is indeed able to induce arteriosclerotic heart disease in 

Dr. Morgan. Dr. Bertell? 

Dr. Bertell. Many of the already published radiation arti- 
cles also include cerebrovascular disease. For example, in the 
ankylosing spondylitis study, class D, which was not supposed to 
be in any way associated with the disease itself, had a signifi- 
cantly high rate of occurrence among the people. This disease 
class D included the cerebrovascular and other circulatory dis- 

The article to which I think Dr. Sternglass just referred 
showed consequences of exposure to ionizing radiation for medi- 
cal specialists and radiologists. Mortality from cancer, cardio- 
vascular-renal disease, and all other causes combined were in- 
creased in societies with high exposure to radiation. 

This is across the board. It also occurs in Hiroshima and 
Nagasaki data but primarily at the low and moderate exposure 
levels, not at the high exposure levels. 

Dr. Morgan. Mr. Jablon? 

Mr. Jablon. For deaths from vascular lesions of the central 
nervous system -- strokes, that is to say -- I do not know just 
what vms meant by low dose, but at the lowest range we have, which 
is zero to nine rads, the mortality in Hiroshima was 74 percent 
of the Japanese standard and in Nagasaki 95 percent. 

So in both cases, it was lower than the Japanese national 

In neither city, is there any radiation group that signifi- 
cantly differed from any other group in terms of mortality from 
that cause. 

For diseases of the circulatory system in Nagasaki, there 
are no significant differences. In the zero to nine rads group 
the mortality ratio was 93 percent of the Japanese standard; ten 
to forty-nine rads, 113 percent. This is up a little bit, but 
the differences were not statistically significant. In Hiroshima 


also there are no differences: zero to nine rads, 85 percent; ten 
to forty-nine rads, 80 percent; fifty to ninety-nine rads, 100 per- 
cent of standard Japanese mortality. 

I do not see any evidence in these data of any effect on the 
circulatory systems. 

Dr. Morgan. Dr. Bertell? 

Dr. Bertell. What I am quoting is a study of mortality of A- 
bomb survivors by Beebe, Kato, and Land.z./ There were deaths from 
allergic diseases, endocrine system, metabolic and nutritional 
diseases. Then there is a good deal of discussion, 53 deaths from 
diabetes among Hiroshima males; 49 deaths from the entire sample 
for 1962-66. 

They go on to discuss the significance of the linear trend, 
then they rule it out as radiation related because it did not oc- 
cur at higher doses. 

The deaths occurred primarily in the age group from 40 to 59 
at the time of bombing. The increased risks of death for diabetes 
mellitus, cerebrovascular disease and heart disease were striking. 
That was where I took the information from: Radiation Research, 
Volume 48, pages 613 to 649. 

Mr. Jablon. I would like to say just one word about that. 

You know that there is, I think a statistical fallacy based 
on the principle, that if you give an event of low probability 
enough chances to happen, it is going to happen eventually. 

You are talking about a report where some twenty different 
causes of death were examined. They were examined separately 
for two cities and for two sexes, That multiplies the comparisons 
by 4. 

Now we have 80 comparisons and there are 5 age groups, which 
makes it 400, and there are several different radiation exposure 
groups which can be contrasted within each of the 400; not to find 
some significant differences in that mass of data merely by chance 
would be incredible. There would be something suspicious if it 
did not happen. 

Therefore, when one finds an occasional discrepancy, one has 
to examine it to see if it makes any sense, whether it is consis- 
tent by city, by sex, by dose or something of that sort. Other- 
wise, you do not know where you are. 

Dr. Bertell. I guess what I think is really remarkable about 
a possible occasional discrepancy is that it also agrees with what 
we found in the Tri -state data. It agrees with what was in sever- 
al other studies. 

I think that was a criterion which the Commission used it- 
self. They said they had performed thousands of tests and the ul- 
timate test would be in agreement with other bodies of data. 


Dr. Morgan. Dr. Bross? 

Dr. Bross. I believe that the discussion has rather charac- 
teristically gone off to the direction it eternally takes. It has 
dealt with an abstract issue. But this is a public health issue 
and it should be dealt with by this panel as such. 

The statement has been made that there is no evidence of hu- 
man beings exposed to low-level radiation. I would say that our 
data is entirely based on diagnostic x-rays which are at this 
level or lower. We are not, and let me emphasize this, we are 
not extrapolating from very high levels to very low levels. We 
are talking about actual data on human beings exposed. In order 
to make this clear, I will say a little about where this data 
comes from. 

It is coming from the Tri-state data on a population base of 
13 million people in designated parts of three states. Nearly 
all the households with cases of leukemia during a three-year 
period and a random sample of households in the same area were 

The persons interviewed were asked about diagnostic expo- 
sures and their exposures were validated against hospital records. 
These costly and arduous procedures, including the double-blind 
interview, and a first-rate staff, headed by Dr. Abraham 
Lilienfeld, assured that these data are just as valid as any data 
produced by an animal study. 

The study size is 13 million persons, not 13 mice. The re- 
source that we have here was, in fact, mentioned in the BEIR 
Report and then ignored. This information gives a clear picture 
from actual data of the hazards of persons exposed to low-level 
radiation. And in fact, if anyone takes the trouble to look at 
the published -- I emphasize published -- literature that I now 
list, there are now one dozen papers, published in quality sci- 
entific journals. 

We are not talking about abstract issues. We are talking 
about public health issues. We are not talking about hypothe- 
tical data; we are talking about real people being killed by radi- 

Dr. Morgan. Dr. Bond? 

Dr. Bond. Dr. Bross, I shall simply add that what data were 
available at the time that the BEIR deliberations were made were 
taken into account. You indicated that your material was re- 
ferred to in the BEIR Committee Report -- I can easily give you 
chapter and verse -- and it was taken into account in the deliber- 
ations of that Committee. 

I have also some of your data with respect to potential ef- 
fects on unborn children. They also were taken into account. 
You have published these in the open literature, and they have 
been criticized. I have the criticisms that indicate that the 
data do not necessarily prove the conclusions that you drew, and 
that there are other conclusions possible from the data. 


Dr. Morgan. Dr. Bertell? 

Dr. Bertell. I would just like to state again, we are not 
really dealing with opinion but hard data, and not only the Tri- 
state data, which I know I have spent five years with and feel 
pretty conversant with, but also if you take a look at the other 
published data from the Hiroshima and Nagasaki and also from other 
studies, you will find that much was reported at low-level as 
unexplainable, and it is in there. It is in the published re- 
ports. This effect was disregarded since it did not become worse 
at higher doses. 

We need to take a new look at that whole body of data which 
is being quoted as supporting standards which I think are no 
longer admissable. 

Dr. Morgan. Mr. Jablon. 

Mr. Jablon. I just wanted to say in response to some remarks 
about hard data that, in fact, there are very few hard data that 
are pertinent to radiation effects in man. We do not make experi- 
ments on men. 

Every one of the studies that has been cited has been an ob- 
servational study. You look at it and try to squeeze out of the 
data, the best information you can get. You never know whether 
the persons who have been radiated are like other persons, or dif- 
fer from them in other respects than the radiation. 

I would like to say also that, on the issue of pre-natal 
radiation, the Tri-state Leukemia Study, a very good study, is 
far from the only study in that field. In fact, data from various 
studies, including one by Dr. Li 1 ienfel d ,5./ whose name was men- 
tioned, are rather contrary. 

Just what the picture is there is not entirely clear. 

Dr. Morgan. I think we had better go on to the next ques- 
tion. Dr. Bross? 

Dr. Bross. I believe there is an issue here before the group 
as a whole that they should recognize. We are being challenged, 

insofar as our epidemiological studies are concerned, by persons 
who not working in this line. 

In the study in Japan, for example, the control was taken as 
under 10 rads, and this is what we are talking about, the under 10 
rad exposure. 

The point I want to make is this. I have half a dozen major 
epidemiological findings to my credit, not in this field alone, 
but in others. If we are going to put this on the basis of who 
knows more about epidemiology, a gentleman that you have heard 
from or me, I think we should put our records in evidence. 

Dr. Morgan. Dr. Archer? 

Dr. Archer. I would like to state here that the answer to 
the problem of very low levels of background radiation can only 


come through epidemiological studies and studies of extremely 
large populations. This approach is feasible because in our 
natural state, as we live in the world, the background radia- 
tion differs in different places. 

These differences in background radiation, from which we 
can demonstrate differences in effects, both genetically and by 
cancer incidence provide the best approach. I think one of the 
problems with this approach in the past has been that we have 
not been measuring our background radiation properly, so we have 
not been able to contrast proper groups. 

May I have my first slide, please? 

We have a new approach, I think, which promises to give us 
some more real information at background levels of radiation. 
This slide is a map of the United States with countours across 
it, which are the countours of the measurement of the horizontal 
component of the geomagnetic forces of the earth. 

The center of the horizontal component is somewhere near the 
southern end of the Hudson Bay. These are the contours of in- 
creasing horizontal geomagnetic force. 

The measurements are in gammas, or gauss. The effect of 
this force on background radiation, especially cosmic radiation, 
is rather fundamental, because this force extends beyond the at- 
mosphere for thousands of miles. 

When the electrically charged particles from cosmic radia- 
tion arrive, they are diverted and their paths are partially 
directed by this horizontal geomagnetic field. By using this 
force as our guideline and choosing our populations for compari- 
son, I think there is a good chance that we can learn more about 
the effects of background radiation. 

Slide two, please. 

This gives the frequency contours of neonatal deaths from, 
congential anomalies based on a report of Dr. Wesley in I960.-' 
These contours across the United States show the highest rate in 
the north eastern part, and lowest rates towards the southern 
part of the nation. 

Slide three, please. 

This slide shows a similar geographic pattern for leukemia. 
It does not correspond exactly with horizontal geomagnetic force 
lines, but it has a resemblance. 

Slide four, please. 

This slide shows distribution of cancer of the stomach. 
Again, you can see the same contours of death rates for cancer of 
the stomach which corresponds roughly to geomagnetic force lines. 

SI ide five, please. 

This shows distribution of breast cancer. These contours 


are similar to the two preceding slides, especially in the east- 
ern part of the U.S. The pattern is less consistent in the west- 
ern states, because the West was settled later, and many of those 
persons who are dying there grew up in the East where the geomag- 
netic levels (and cosmic radiation) are higher. 

That is all of the slides. 

Essentially what I am trying to point out is that in past 
studies what has been measured as background radiation is mainly 
gamma radiation. That does not differ very much over the nation. 
In fact, the highest level of gamma radiation is in Colorado which 
does not have the highest rates for congential anomalies or cancer 

I think what we have been overlooking in these background 
measurements are the particles. There are a lot of nuclear par- 
ticulates in the cosmic radiation which have been discovered since 
earlier studies were made, and these particles are the components 
of cosmic radiation that are influenced by the geomagnetic fields. 
Some of these particles are ten to over 100 times as efficient in 
producing chromosome injuries as gamma rays are. 

\! Stewart, A., Webb, J. and D. Hewitt. Survey of Childhood 
Malignancies. British Medical Journal, v. 1. 1958: 1495-1508. 

y Gibson, R.Q., Graham, S., Lilienfeld, A.M., Bross, I. et al . 
Leukemia in Children Exposed to Multiple Risk Factors. New 
England Journal of Medicine, v. 279. Oct. 1968: 906-909. 

y Bross, I. and N. Natarajah. Leukemia from Low-Level Radia- 
tion; Identification of Susceptible Children. New England 
Journal of Medicine, v. 287. July 1972: 107-110. 

4/ Beebe, Kato, and Land. Study of A-bomb survivors. Radiation 
Research, 1971: 613-649. (The fourth report in a series.) 

5/ Diamond, E.L., Schmerler, H., and A.M. Lilienfeld. The Rela- 
tionship of Intra-Uterine Radiation to Subsequent Mortality 
and Development of Leukemia in Children. American Journal of 
Epidemiology, v. 97. May 1973: 283-313. 

y Wesley, J. P. Background Radiation as the Cause of Fatal Con- 
genital Malformations. International Journal of Radiation 
Biology, v. 2. 1960:97-118. 


79-767 O - 76 - 3 


Chapter IV 

Dose-Response Relationships, Linear or Non-Linear? 

Dr. Morgan. Let us go on to the next question. 

Question 3: Do these effects that we are talking about in- 
crease linearly with increasing dose? 

I believe data suggests that the cancer risk can in a sim- 
ple way be expressed by an equation such as, R, the risks, equal 
a constant, C, times the accumulated dose, D to some power, N in 
other words: 

R = CD^ 

In the case of low LET radiation, for example, X, gamma and 
beta radiation, the accumulated dose, D, must be corrected for 
repair of damage over time, as pointed out by Dr. Bond in which 
it does appear in most cases that N is equal to or greater than 
1, suggesting the greater efficiency of multiple hits. 

In the case of high LET radiation, however, such as alpha 
and fast neutrons, there seems to be little or no repair and best 
fit curves are obtained when N is less than 1, indicating the 
damage per rem is greater at lower doses. 

Dr. Baum (J. Baum, Health Physics Society, Houston, Texas, 
1974) and many others have shown that in the case of human ex- 
posure to radium the best curve fit for cancer induction is when 
N is equal to 1/2. Thus, for high LET radiations, such as those 
from Plutonium 239, the linear hypothesis underestimates the risk. 

In a recent paper,-/ I gave five additional reasons why the 
linear hypothesis as now applied is nonconservative. I might 
summarize as follows: 

1 - Extrapolations are often made to zero of effects on 
animals and man, and they are sometimes extrapolated from the 
high dose descending portion of the parabolic curve where there 
would be overkill . 

2 - Estimates are made from exposures to animals of short 
life spans, and for a man (as pointed out in the BEIR Report), 
out to only about twenty years. Of course, other data over the 
remainder of man's life would have to increase the slopes of 
these curves or the risks per rem. 

3 - A uniform population is usually assumed taking little 
account of the age distribution and the disease patterns, as Dr. 
Bross has pointed out. 

4 - There is cell sterilization at the higher doses and so 
it is somewhat risky to extrapolate from these doses because you 
would underestimate the risk at low doses. 

5 - I think quite important is the fact that recent data 
from Drs. C.W. Mays and H. Spiess on radium 224, a bone surface 


like Plutonium and other actinide elements, indicate that the can- 
cer risk increases with protraction of the dose. This is just the 
opposite of what we have observed from low LET radiation. 

In summary, I would state that it is my opinion that the 
linear hypothesis is always nonconservati ve for high LET radia- 
tions. Usually it is nonconservative for in utero exposure of 
children to low or high LET radiations, but in some cases of adult 
exposure, it is probably conservative for low LET radiation. 

I am sure I have provoked a lot of discussion. 

Dr Morgan. Dr. Sternglass. 

Dr. Sternglass. I would like to say that at the recent hear- 
ings by the EPA on radiation standards for the nuclear fuel cycle 
I presented evidence obtained by many people in the literature 
that at the very low dose rates that we are talking about, we are 
dealing predominantly with a different biological mechanism than 
we are dealing with at the high dose rates. 

The recent data by Dr. Petkau-?/ show that as the dose rate 
decreases, it takes less and less dose to break a cell membrane. 
This evidence was not available at the time of the BEIR Report. 

What it means is simply this, that for somatic, not gene- 
tic situations, we are now faced with a whole new problem, namely 
the fact that when cell membranes are injured as a result of 
indirect chemical effects the data of Dr. Petkau both for free 
membranes and his new data on micro-organisms and mice, show 
clearly that the lower the dose rate is, the less it takes to 
break a membrane. 

As a result, one is led to a non-linear effect at low doses, 
which is opposite to what we had expected in the past. In fact, 
the curve of response versus dose goes up much more rapidly at 
the origin to the degree that this leads to an under-estimate of 
biological effects of very low doses using a linear extrapolation 
of something like a few hundred, possibly as much as a thousand- 

Now recent studies have shown that membranes are involved in 
the functioning of the immune system of the body. One of the 
most important things about the immune system is that it not only 
defends the body against viruses and bacteria, but we now know 
from recent evidence published in the last few years, that the 
immune system also detects and controls cancer cells. 

Thus, we are now faced with the evidence that cell membrane 
damage is possibly the controlling one in cancer induction at low 
dose rates, while at high dose rates, the controlling process 
seems to be direct damage to the DNA. 

This means that we now have a mechanism that we did not have 
before that can explain not only the very large increases in in- 
fant mortality, but also the changes in heart disease and cancer 
all over the world following the period of nuclear testing. 

These kinds of data were simply not available before Dr. 


Petkau's data and the recent studies on animals at low dose rates 
became available. 

I agree with the Chairman, Dr. Morgan, that we have evidence 
that protracted radiation at both low and high LET in some circum- 
stances may be more effective in producing damage than we expected. 

It is precisely to this point that I would like to address 
mysel f . 

I would like to show, very briefly, with the help of a couple 
of slides, the nature of the evidence that indicates that we have 
such a problem. (See Figure 2.) 

Now, this is the data of Dr. Petkau which shows very clearly 
that, as you go down in dose-rate from right to left, the dose 
required to break a cell membrane declines. In fact, it takes 
3,500 rads to break a membrane with a brief pulse of medical x- 
rays. But it takes less than one rad to break it at one millirem 
per minute. 

Therefore, as one goes down towards background dose-rates, it 
is more easily broken. This has now been shown also in living 
organisms by Dr. Petkau contrary to what Dr. Bond has said. 

Secondly, I would like to show that a much greater than ex- 
pected effect at low doses and dose-rates also has been recently 
confirmed in animals studies for polonium, published by J.B. Little 
and co-workersl/ . (See Figure 2.) It shows at very low doses 
the risk of cancer goes up very sharply near the origin, then 
levels off at high doses, exactly as one would expect for a mem- 
brane-type effect. 

It shows that only towards higher dosage is the curvature of 
the dose response curve concave upward. 

If one extrapolates from the high doses, as we have in the 
past and as was done in the BEIR Report, and draws a straight 
line to the origin, one greatly underestimates the effect that 
would occur at very small doses near zero, and this has now been 
found in a number of animal studies, including that of Dr. 
Sanders at Battel le-Northwest Laboratories and other animal stu- 
dies . (See Figure 4. ) 

The fact that it can also be seen in human populations is 
perhaps most strongly illustrated by the changing cancer rates in 
Japan between 1920 and 1965 or '70. (See Figure 5.) Here we see 
that between 1920 and 1950, during the period of enormous increases 
in industrial and chemical pollution and the addition of food 
additives, there was no significant rise in cancer, and that the 
rise in cancer began within three to four years after Hiroshima 
and the huge tests in Siberia that dropped heavy radioactive fall- 
out on Japan. 

Furthermore, the upper line shows what happened to the U.S. 
non-white population that includes, of course, Japanese, Chinese, 
Indians and Negro populations in this country. It shows an enor- 
mous, sharp rise beginning a few years after the fall-out began 




0.001 0.01 0.1 

DOSE RATE (rad/min) 

Data of A. Petkau, Health Phvsics 22, 
239 C'arch, 1972) 

Figure 2 




(J. B. LITTLE et al. Science / 

/ / 


Moy 16, 1975 , VoL 188, p.737 

100 200 


Figure 3 


(C.L. SANDERS, RAD. RES. 56 , 540, 1973 ) 

100 200 500 400 


Figure 4 


< 150 




2 100 



all ages, all sites, rate per 100,000 
( M. Segi et al. , 
Japan Cancer Society) 







50 - 













1920 *30 

*40 *50 

*60 '70 

Figure 5 

to come down, with doses that were never much greater than 20 to 
50 millirems per year, showing a brief decline four to five years 
after the test moratorium, and rising again following the second 
increase in fall-out from the second test-series. 

Furthermore I just received data from Japan, from Dr, M. 
Segi in Japan, that shows that beginning in about 1970-71, cancer 
rates have begun to turn around in Japan, halting their rise sud- 
denly and actually beginning to drop for prostate cancer, leuke- 
mia and other cancers of relatively short latency period. 

In fact, I will show you the case of how dramatically one 
cancer in particular rose, which medicine has been unable to treat 
successfully, namely cancer of the pancreas. (See Figure 6.) It 
shows that it was completely level and horizontal during the time 
of the worst chemical pollution between 1930 and 1945 and then 
shot up 1200 percent in a matter of a few years. 

Anyone who can say that this does not suggest the possi- 
bility that we seriously underestimated the effect of very small 
levels of radiation does so at the risk of disregarding public 

I would like to point out what I think is sometimes not 
clearly understood. I fully agree with you that at this moment 
diagnostic x-rays are the source of the greatest x-ray exposure 
to our population. However it now appears in the light of the 
new evidence of greater effects at the very low dose rates, that 
at the rates of environmental radiation, we are experiencing a 
phenomenon for which we were not prepared by our studies of medi- 
cal x-rays. It is suggested that because medical x-rays are given 
at a very high dose rate, they may have a much smaller somatic 
effect for a given dose. I would just like to illustrate this 
with one slide here that I believe makes it clear how this error 
came about, since we did not have any of this experimental infor- 
mation until about three or four years ago. (See Figure 7.) 

What I have here is a plot of the so-called critical doubling 
dose in rads going from 1/1 000th of a rad up to 100,000 rads as a 
function of dose rate, where the dose rate is given in rads per 
minute. In the middle we have about one rad per minute. For the 
bomb radiation, we have about a thousand to ten thousand rads per 
minute. For fall-out, we have about 1/10, 000, 000th of a rad per 

All of our previous standard-setting and all of our medical 
experience is based on the assumption that the genetic damage is 
dominant and that the dose needed to double the normal incidence 
is about 10 to 100 rads, and that this applied to cancer also. 
Most importantly, it was assumed that this was essentially inde- 
pendent of the dose rate. 

However, our medical experience only extended roughly from 
10"-^ rads per minute up to the A-bomb radiation rate of a few 
thousand rads per minute, but the portion of the curve between 
10-3 and lO''' rads per minute had remained essentially unexplored 
either in human or animal studies. It was only in the last few 
years that Dr. Scott and other researchers began to investigate 



Figure 6 

I0~° . 10 


(50-150 mr/yr) 





10° RAD/MIN. 

Figure 7 

what happens at the extremely low dose rates for which we had no 
medical data. 

What I am now suggesting on the basis of this new data is 
that the cell membrane damage seems to be coming into dominance 
at these low dose rates and that this could explain why we were 
misled by our relatively fortunate experience with medical x-rays. 
In fact, when I wrote my book in 1971, I was absolutely convinced 
that linearity was the best possible choice to make for estimating 
the likely effect of background radiation. But in view of these 
new discoveries of membrane damage and its relation to the immune 
process, I seriously question whether medical radiation is indeed 
the greatest source of our biological damage, although it is cer- 
tainly true that it is the greatest source of our exposure. But 
it is given at a very high dose rate and this, I believe, is cru- 
cial and needs much further investigation. 

Certainly the fact that in Japan for 30 years between 1920 
and 1950 the cancer rates did not rise throughout the period of 
growing use of medical x-rays as Dr. Segi's data shows, I believe 
indicates that medical diagnostic x-rays, although they are large 
in dose, fortunately are not the biggest source of our cancer 

Dr. Morgan. Dr. Richmond? 

Dr. Richmond. I think I would like to respond to the comment 
that was made by the previous speaker. Dr. Sternglass. 

The public has been exposed very often to claims that there 
are increases in infant mortality, of various diseases, cancer, 
etc., as a result of releases of materials from nuclear facilites. 

I think that the record clearly states that in every case 
where this allegation has been made, investigations followed by 
responsible state or Federal agencies did not support the alle- 
gations. They were all found to be false. 

Dr. Sternglass. That is not the case. As a matter of fact. 
Dr. Morgan was present at one of these hearings. All that could 
be said was that it was not possible to decide with the particular 
data in a single situation whether or not the observed rises and 
declines in cancer rates and infant mortality were, in fact, 
definitely associated with radioactive releases. 

Dr. Morgan. Dr. Bond? 

Dr. Bond. I would like to state, in response to Dr. Stern- 
glass, that the data to which he referred, by Dr. Petkau were ob- 
tained on non-living materials. It is difficult enough to extra- 
polate from lower living materials to man, let alone from non-liv- 
ing material . 

With respect to his responses to Dr. Richmond. I would like 
to say I have in front of me a single document. 1/ It is a sum- 
mary of responses to ten years of allegations that Dr. Sternglass 
has made. The overall conclusions from detailed analyses of the 
same data that he has used with respect to infant mortality are 


that, without exception, the conclusions Dr. Sternglass has drawn 
with respect to infant mortality were not supported by the data 
presented by Dr. Sternglass. 

Dr. Morgan. Dr, Mattson? 

Dr. Mattson. Mr. Chairman, I think we should try to get back 
to the agenda, and the issue at hand today. People have said sev- 
eral times around the panel that the issue is a public health is- 
sue. The primary concern of this public health issue is the set- 
ting of radiation standards to protect people. 

What we have heard in this opening dialogue is the nitty- 
gritty of the scientific research. It is important research, but 
the dialogue does not help us get directly to the question of 
whether the standards are any good. 

I thought that I ought to say something on this, because this 
is my job as a regulator, as a protector of public health and 
safety and one who works with standards. These are the kinds of 
decisions we make day in and day out. Given the tens of thousands 
of reports by people like those reviewed by the BEIR Committee and 
by some of you here today, how do we come to a consensus of scien- 
tific opinion of how to protect people from low levels of radia- 

I think Dr. Morgan said it well at the start of this question. 
There is no hard, direct evidence of a link between health effects 
and low-level radiation. Despite that, radiation standards today 
are set assuming that there is a direct relationship. 

That is what the linear hypothesis is all about. We use a 
linear dose/effects dependence, that is, the same number of ef- 
fects per unit of dose that is observed for high level radiation. 
We continue to study that dependence. There are millions of dol- 
lars of research going on in the kinetics of cancer, carcinogene- 
sis. And dialogue continues day by day. Even with this ongoing 
research, we prudently assume such a linear relationship in the 
standards that are set today. 

Dr. Morgan. I would like to take prerogative as the Chairman 
to respond to the exchange of information or statements between Dr. 
Sternglass and Dr. Richmond. 

Dr. Sternglass was correct in his response with reference to 
the Shippingport reactor. I happen to have been a member of the 
Governor of Pennsylvania's Committee to look into the allegations 
of Dr. Sternglass' referencing the increased incidence of ailments 
in the population as a consequence of this operation. 

My interpretation as one member of this committee was that 
there were no data, no evidence, of statistical significance that 
the operation of this reactor had resulted in these effects claimed 
in the allegations of Dr. Sternglass. But, on the other hand, the 
data were so poor and the information collected from environmental 
monitoring as far as health physics was concerned were of such poor 
quality, and there were so many corrections to these data and the 
biological effects, it was impossible to rule out the fact that there 
may have been a relationship between environmental radiation exposure 


from the Shippingport operation and an increased death rate in the 

Dr. Morgan. Dr. Bond? 

Dr. Bond. In 1972, two very extensive studies were made by 
two groups, the United Nations Scientific Committee on the Effect 
of Atomic Radiations5./and the BEIR Committee of the National Acad- 
emy of Sciences. It was made well-known that these studies were 
going to be done, and information was solicited from all scien- 
tists -- from anyone who wished to submit information. 

These two groups studied the same bodies of evidence. In 
some ways they came to the same conclusion; in some ways, to dif- 
ferent conclusions. They studied both the genetic and somatic ef- 
fects, and they took into account the various effects that have 
been mentioned so far in the conversation today. 

In the UN Report it was recognized what has been know for de- 
cades, that radiation does produce long-term effects, such as can- 
cer. It was shown that quantitatively one can draw deductions 
with respect to effects in the high dose and dose rate ranges. It 
was stated that the data were insufficient to allow one to extra- 
polate or, more accurately, interpolate with any degree of accur- 
acy to effects at low doses and those rates. 

Both reports came basically to the same conclusion with re- 
spect to the effects of high doses and dose rates. I will not 
give the derived risk coeff iciencies , since they are well-known. 

The BEIR Committee did use so-called linear extrapolation to 
obtain what is considered to be an upper estimate of what might 
happen at low doses and dose rates. I am speaking entirely of low 
LET radiation; not high LET radiation. 

They did use so-called linearity, a straight line, between 
effects obtained in high doses and dose rates and background ef- 
fect, at zero dose. 

In this group it was discussed extensively that recovery oc- 
curs in all known biological systems. It was actively discussed 
in the BEIR Committee Report Group, whether or not a dose rate 
factor should be incorporated into the risk estimates. It was de- 
cided that they should not, because, on the basis of purely human 
data, one could not make a definitive statement whether dose rate 
effects obtained, or did not obtain, and, in the Committee's esti- 
mation, animal data were not sufficiently developed. 

Since that time, a large amount of animal data has become 
available, and the current discussions in the scientific community 
generally are that, on the basis of animal data and not contradicted 
by other data, one should in fact, introduce a dose rate factor. 
This would reduce the effects predicted in the BEIR Report. 

The BEIR Committee Report has been discussed extensively, and 
its findings in general have held up. It is one of the best com- 
pendia of radiation effects data, in my estimation. 

Thank you. 


Dr. Morgan. Dr. Martell? 

Dr Martell. My comments are directed to some of the re- 
marks that Dr. Bond made regarding the inadequacy of the BEIR 
Report. To keep the record straight, I must point out that when 
the BEIR Report was prepared, no adequate consideration was given 
to the role of internal emitters, particularly internal alpha 

The "hot particle" hypothesis had not been discussed. This 
hypothesis involves some rather serious implications about cancer 
risks from plutonium which are only now being considered. This 
was not touched upon in the BEIR Report. I have raised some ad- 
ditional questions with respect to the cancer risks for insoluble 
alpha emitting particles of moderate activity in human soft tis- 
sue. This issue has also never been discussed. 

The whole question of cancer risks which are associated with 
internal alpha emitters has been averaged away by averaging organ 
burdens and alpha doses without considering the micro-distribution 
of alpha emitters in soft tissue and the possible consequences. 
In this connection, the real issue is whether or not a multiple 
mutation process may be applicable to internal alpha emitters in 
the chronic exposure case. If it is, we have seriously underesti- 
mated the health effects of internal alpha emitters. 

This omission extends to genetic effects as well, particular- 
ly because in the BEIR Report it was assumed that internal emitters 
contribute only 18 percent, uniformly, to the gentically signifi- 
cant background radiation dose. Anyone who has looked at the in- 
ternal radioactivity distribution in human organs finds that there 
are wide variations for natural and artificial radioactivity. We 
now find, in publications over the last several years, that pluto- 
nium is present in the gonads at concentrations relatively high 
for soft tissue organs with a distribution that will give rise to 
even higher radiation doses to the sperm. And it has been known 
for some time that for polonium-210, in smokers, there is a much 
higher concentration in the sperm than elsewhere in the gonads. 
I suggest that internal emitters and their micro-distribution in 
gonads, and alpha emitters in particular in the sperm and the ova, 
are a serious and almost completely neglected subject. If you 
read Chapter VI of the BEIR Report, you get the impression that 
only a few percent or less of human genetic effects are due to 
radiation and that the rest are somehow due to nonradioactive mu- 
tagens. However, it is likely that alpha emitters and other in- 
ternal radioisotopes play a very important role in accounting 
for the remainder of the genetic effects in man. 

Dr. Morgan. Dr. Richmond? 

Dr. Richmond. I would like to respond to some of the com- 
ments that were just brought up by my colleague. Dr. Martell. 

Two items, specifically, one in reference to our alleged lack 
of knowledge or state of ignorance about non-uniform distribution 
of plutonium and actinide elements in man. I think that this can 
best be summarized by what is currently known as the hot particle 
hypothesis that was submitted to several government agencies about 2 


years ago in the form of a petition to lower the standards for occu- 
pational exposure, actually by a factor of 10^, about a hundred- 

I will just read to you there is quite a bit of literature 
available on this -- some of the organizations that have studied 
this question and have not been able to support the hypothesis. 

This means that they have not found it scientifically valid 
to support the hypothesis that there is a serious defect in the stan- 
dards. Alternatively, they have condoned the current means of cal- 
culating radiation standards. These include the National Radiolo- 
gical Protection Board of the United Kingdom, and the Biophysical 
Society of the United States. 

These reports were all published or are available to the public. 
The National Radiological Protection Board in the U.K. I mentioned. 
There are numerous documents that have been written and assigned to 
the literature. I will not go into all of these, as there are a 
great number. There have also been Federal hearings by the Environ- 
mental Protection Agency held in 1974 that considered this issue. 

The Medical Research Council of the United Kingdom has reviewed 
the issue. The National Council on Radiation Protection in this 
country has reviewed the issue. The Nuclear Regulatory Commission 
has reviewed the issue. The National Academy of Sciences is current- 
ly reviewing the issue. 

I think a very good summary is published in the Federal Regis- 
ter, Volume 41, Number 71, April 12, 1976. (See Appendix.) This 
was a rejection of a hypothesis by the Nuclear Regulatory Commission. 

The other issue brought up related to our lack of information, 
allegedly again, on plutonium and actinides in gonad tissue. I again 
refer to the time-honored mechanism of scientists that we publish in 
the literature. Here is a recent article on the concentration of 
Plutonium and actinide elements in the gonadal tissues of man. This 
is published in the Health Physics Journal. Our esteemed Chairman 
has been associated with the journal for many years. 

In summary, this shows that there was not a selected concentra- 
tion of plutonium in gonadal tissue, including samples obtained from 
people. We do understand the effects of radiation, including high 
LET, highly ionizing radiation, on gonadal tissues. 

Thank you. 

Dr. Morgan. Thank you. Dr. Caldicott? 

Dr. Caldicott. I am not so sure how we are going to set stan- 
dards, or how the present standards will represent what will happen 
in the future when we proceed with nuclear fission and the breeder 
reactor and produce massive quantities of fission products. We know 
we lack a lot of the stuff already. We know two years ago in Hanford, 
Washington there was a leakage of 115,000 gallons of highly radioac- 
tive waste products into the soil. 

We know where it is, but we cannot stop it. It is approaching a 
river I cannot remember the name of the river -- the Columbia river. 


We know that these fission products are concentrated in the 
food cycle; radioactive elements are all concentrated in the food 
cycle, in milk in particular. We know that babies drink milk. 

We know that 3 microcuries of plutonium deposited in the lung, 
which is a small amount, over a period of one year will produce a 
radiation of the total lung of 2,000 rems. 

I do not think that is a low radiation, but it is a small 
amount of plutonium. 

This recent paper suggests that plutonium is concentrated in 
the gonads compared to the lung and absorbed from the lung, not the 
gut, by a factor of 2. It is concentrated in the gonads by a fac- 
tor of 2. 

I really do not quite understand by the standards we have now 
how we are going to control and monitor this when we indulge in 
breeder reactors for future generations. 

Dr. Morgan. Any further comments on this question? 

Dr. Richmond? 

Dr. Richmond. You have raised many points. I will only stick 
to the last one. 

You mentioned that there is evidence that there is a concen- 
tration of plutonium in the gonads relative to the lung. I happened 
to write that paper, and that is not the conclusion. It is one that 
you can draw from it, but the point, the conclusion, was made that 
there was no selective concentration of plutonium in the gonadal tis- 

It is quite interesting that the data show that there is no con- 
centrating mechanism in the soft tissues. There can be a concentra- 
tion in the lymphatic tissues because of the pathway by which the 
plutonium gets from the lung to the regional lymph nodes. But there 
is no appreciable concentration in soft tissue. 

If you look at statistics of the situation, for example, some 
people have looked at that particular set of data and made, I think, 
wrong conclusions -- if you stop to think about it, all the material, 
if inhaled, is in the lung at some time and at some later time it is 
somewhere else. So the level in the lung decreases while it is in- 
creasing in other tissue. 

I would argue that point very seriously. That is all. 

Dr. Morgan. Dr. Martell? 

Dr. Martell. Thank you. 

I would like to add a comment with respect to the critique of 
the linear hypothesis that Dr. Karl Morgan made. 

I think he has made an excellent statement to indicate why high 
LET radiation, for several reasons, may involve higher effects at 


79-767 O - 76 - 4 

very low levels and why it is not conservative to extrapolate to very 
low doses of radiation. 

In this connection, a study that I have been carrying out, in 
cooperation with two other research groups,^/ shows that insoluble 
alpha emitters are present in cigarette smokers' lungs. 

And the small amount of alpha activity involved can only contri- 
bute to cancer induction in smokers if a multiple mutation process 
is involved. However, if a multiple mutation process is^ involved, 
the linear hypothesis would be seriously in error and we could have 
very much higher risks for longer exposures to very small burdens of 
insoluble alpha emitting particles. 

This arises from the fact that, for a multiple mutation process, 
one has a self-proliferation of the singly mutated cells taking place 
continuously, so that the risk of getting a second particular change 
in the same cell is proportional to that number of singly mutated cells 
only some of which have been directly induced by radiation, but each 
of which will have proliferated according to the mitotic activity of 
the cells being irradiated. 

As we all know, the mitotic activity is higher for cells in some 
organs, and higher in the young. Therefore, the cancer risk will 
increase very significantly for the chronic exposure case, and the 
earlier such exposure begins, the earlier the effect and the higher 
the risk. 

Dr. Morgan. Dr. Bertell? 

Dr. Bertell. I would just like to add here that sometimes the 
phrasing of the question is misleading and I would submit that the 
question: "does radiation have a linear dose effect," is too sim- 
plistic for the type of thing with which we are dealing. 

In the first place, there are multiple effects, and in the 
second place, I think we are dealing with different biological mech- 
anisms . 

Unless we refine the question and say: "is this particular 
mechanism linear," or: "is this particular result appearing in a 
linear fashion," we are obscuring the public health question. 

Dr. Morgan. Thank you. 

Dr. Archer? 

Dr. Archer. Yes. 

May I have my sixth slide, please? 

I have been engaged in studying uranium miners for more than 
twenty years now -- not quite that long, but when we first set Feder- 
al standards for them in 1957, I drew an exposure response curve for 
lung cancer with all the data we had at the time. Exposures were un- 
certain, and the populations were not well defined. We made estimates 
of exposures and populations, and drew some curves which I extrapo- 
lated to zero dose and zero response. I suggested this be used for 
setting the standard. 


It was rejected because first the points were somewhat uncer- 
tain. Secondly, there was very little information down at the lower 
end of the curve. In the years since then we have gathered quite a 
bit of information which strengthens the lower end of the curve. 

Slide seven on the screen represents some relatively new data 
on people who have been exposed to radiation of alpha particles from 
radon daughters in ground mines. The points with the "X" on them are 
from American studies of underground uranium miners. Of the other 
two sets of points, one is from Czechoslovakian uranium miners, and 
the other set of points is from Swedish iron and lead mines. 

There were fairly good exposure measurements for all three. This 
is in the low exposure range, from zero to about 600 Working Level 
Months (equal to 1000-1500 rads). You can see that the line goes up- 
ward to the right into the thousands of Working Level Months. 

The incidence, that is the cancer death rate for lung cancer, is 
given on the left axis. The up and down marks give the standard er- 
ror for each one of the points. I have drawn one line through the 
points by eye. There appears to be an upward bulge near the bottom 
end of the curve. 

The exposure-response line is straight (linear) except that it 
appears to have an upward bulge before it comes down to zero, al- 
though the points are sufficiently uncertain that we cannot be com- 
pletely sure of that. 

Slide eight please. 

We took these sets of data and analyzed them with a linear re- 
gression analysis. This slide gives the curve resulting from that 

One of the other things I should point out, I subtracted the 
expected or background lung cancers from all the points. The numbers 
of these "expected" cancers are not precise, but reasonably good. 
What we are dealing with in these slides are those cancers attributed 
to the exposure. The two outside lines in this slide are the 95 per- 
cent confidence limits. The lower 95 percent confidence limit barely 
reaches the zero point. 

Since we are making the curve linear, that little bulge near the 
bottom pushes the lower end of the curve up, so it looks as if the 
point at which the regression line intersects the ordinate is con- 
siderably above the zero point, which I am sure it cannot really do. 
The bulge at the lower end of the curve may or may not be real. If 
it is real, it means that at very low dose rates, alpha particles 
are more efficient in producing chromosome damage than they are at 
higher dose rates. 

Thank you. 

Dr. Morgan. Dr. Bross? 

Dr. Bross. In order to be clear on a point, which is an excel- 
lent one, which Dr. Bertell made: The effects I want to talk about 
are the accumulated genetic degradation and the relationship, the 


CD r-H cr> 

C3 -3" -3- 
I— » U3 

'A'd OOO'OT/SHIVBQ y33NV3 mi 

question of linearity, with respect to cumulative genetic damage. 

We know that radiation produces minute damage points in the 
delicate biochemical structure, DNA, of the genetic material of hu- 
man cells. We know this very well from human data, that is, from 
clinical studies at the kilorad level where the radiation produces 
multiple damage points. This particular damage is immediately vis- 
ible because a cell cannot reproduce effectively. As were mentioned, 
multiple hits are required to block the actual reproduction. Where 
you get only a few hits, which must be the case for the cells to 
either show up as cancer in human beings who are exposed to radia- 
tion, or in the children of that person, then you have to have, in 
both cases, a genetic change. 

Then you have a different situation. 

Incidentally, the reason that kilorad doses are used to treat 
cancer are not that they fry cells alive, but that they produce 
heavy genetic damage. The damage points are roughly proportional to 

However, in low level radiation, you get all the damage showing 
up, if you are lucky or unlucky, in the subsequent generations. Where- 
as if you get into heavier damage, heavier concentration of damage, 
you simply block reproduction and you do not have this effect showing 

Dr. Morgan. Dr. Sternglass? 

Dr. Sternglass. Briefly I would like to show why this is exact- 
ly why the leukemia rate in Japan appears to have gone up so very much. 
I would like to show these slides to indicate what damage in the early 
fetal stage, which we all agree is the most sensitive, can do if it 
happens during the critical time of cell division. (See Figure 8.) 

This is taken from Dr. Segi's data on the rise of the incidence 
of cancer mortality, both leukemia or cancer mortality of all types 
in Japan for the 1940 to 1965 period, and this is per hundred thousand 
children, age 5 to 9 years. 

You can see that before the bomb, 1935 to '40, there was essen- 
tially no rise, in fact possibly a slight decline, in the incidence 
of leukemia and childhood cancer mortality. This age group of five 
to nine-year-olds for which Dr. Segi gives the data is the one that 
Dr. Stewart found to be most responsive to x-rays during pregnancy 
in her extensive epidemiological studies in England. 

You can see that suddenly, within a matter of a few years, ex- 
actly as we have seen in the case of diagnostic x-rays during preg- 
nancy, or within about five years there is an enormous rise in can- 
cer, essentially a 200 percent increase in the first two and a half 
years beginning in 1950. When the number of low-altitude A-bomb 
tests leveled off and the high-altitude H-bomb tests began, the can- 
cer rates leveled off. Then, following typically on the order of 
five to six years after the second test series, there was another 
peak, and the latest data show that the cancer rate has begun to come 
down again, which is exactly what you would expect. 


for 5-9 Yr. old moles 
in oil of Japan 
( From M. Segi el al., Japan Cancer Society) 

1^^ U.S.S.R 

5 YR.f 
|il f DELAY 



(41 CASES PER YR. Av. ) 

600 7o 




% a: 

1940 '50 *60 


Figure 8 

This, therefore, is one way to show why we have so underesti- 
mated the effects of fall-out, because the exposure happens during 
the earliest times, during the time when the fetus is most sensitive. 

But not only does cancer increase, but there have been changes 
also in the ability to fight infections, which radiation is known to 
be able to affect. (See Figure 9.) 

I am showing here a plot of pneumonia and influenza mortality 
in the U.S., again for infants who received radiation in the fetal 

We can see here for the entire period 1940 to 1975 first the 
sharp drop up until 1945 to 1950 and then a levelling off of mor- 
tality rates, actually rising again during the time of greatest fall- 
out in 1956-57. 

Finally, a renewed drop in mortality rates took place after the 
end of testing that has now begun to approach what one would have ex- 
pected if there had not been a period during which the fetus was ex- 
posed to enormous amounts of internal isotopes. 

We are dealing here with a total number on the order of 9,000 
to 10,000 infants per year during the 50's. This is clearly not a 
small statistical change. The rate is now dropping down again, so 
it had not reached its lowest possible level during the 50's. 

One could not say that our penicillin and our drugs had done 
all they could. In fact, during the last few years, the pneumonia 
and influenza rate has resumed its rapid decline. 

This suggests that the most serious effect of low-level radia- 
tion in terms of total numbers is not the induction of cancer, but 
really the effects on the immune system of the human body. 


pneumonia and influenza 

1/1 MORTALITY ( - I yr. ) 


1940 '50 '60 '70 '80 


Figure 9 

]_/ Morgan, Karl Z. Suggested reduction of permissible exposure to 
Plutonium and other transuranium elements. American Industrial 
Hygiene Association Journal, v. 36, August 1975: 567-575. 

y Petkau, A. Effect of ^^f^a"*" Qp g Phospholipid Membrane. Health 
Physics, V. 22, March 1972: 239-244. 

y Little, J.B., et al . Lung Cancer Induced in Hamsters by Low 
Doses of Alpha Radiation From PI utonium-21 0. Science, v. 188, 
May 16, 1975: 737-738. 

4/ Yulish, Charles B, et. al . Low Level Radiation: A Summary of 
Responses to Ten Years of Allegations by Ernest Sternglass in 
Proceedings of the Fifth International Conference on Science and 
Society. Herceg-Novi , Yugoslavia. Charles Yulish Assoc. New 
York. July 9, 1973. 

y United Nations Scientific Committee on the Effect of Atomic Rad- 
iation. Report to the General Assembly: Ionizing Radiation: 
Levels and Effects. Vols. I and II. New York. United Nations 
Publications. 1972. (E 72-IX-17). 

6/ Radford, E.P. and E.A. Martell, "Polonium-210: lead-210 ratios 
as an index of residence times of insoluble particles times from 
cigarette smoke in bronchial epithelium", Proceedings of the 
Fourth International Symposium on Inhaled Particles and Vapours , 
Edinburgh, 22-26 September 1975, Pergamon Press, Ltd., and 
Martell, E.A., "Tobacco radioactivity and cancer in smokers", 
American Scientist , 63, 404-412, July-August 1975. 


Chapter V 
Protection of Special Group s 

Dr. Morgan. Going on to question four. What are the various 
subgroups besides the general population whose exposure to radia- 
tion deserves a special attention, such as uranium miners, workers 
at operating reactors, reprocessing plants, etc.? 

Dr. Caldicott? 

Dr. Caldicott. I would like to point out as a pediatrician 
that there are sections of the community who are far more sensi- 
tive to the radiation than others and to these individuals you 
cannot apply the linear hypothesis necessary. Infants are 11 
times more susceptible to radiation than adults. Older children 
are four times more sensitive to radiation. 

Children who have asthma between the ages of one to four 
have 3.7 times the risk of developing leukemia from radiation. 
Children who have allergic disease and who have had inter-uter- 
ine x-ray exposure have 24.6 times the chance of developing leu- 

The reason that children and fetuses are so susceptible to 
radiation is because the cell? are rapidly dividing, and it is 
these rapidly dividing cells that are sensitive to radiation. 
Extrapolating from this, the fetus in the first three months is 
the most sensitive organism in the human life cycle to radiation 
because all of the organs of the human being are being formed in 
the first three months of gestation. 

There are several effects that can occur from radiation 
during this period. There can be damage to the developing or- 
gans. There can be congenital heart disease or various congen- 
ital deformities. 

This is caused by somatic mutation or mutation in the de- 
veloping cell that is formed in that particular organ. 

The fetus can be damaged by a mutation within its gonads, 
the testes or the ovary, which therefore transmits this mutation 
to future generations. There can be damage from another point of 
view, from a carcinogenic point of view, in that one of its cells 
may be damaged and the regulator gene that controls the rate at 
which that cell divides is damaged and the cell may divide. 

Hence, the fetus is extremely sensitive to radiation. 

Dr. Morgan. Dr. Bond? 

Dr. Bond. I certainly agree with what has been said. This 
has been recognized for a number of years. It is taken into ac- 
count very extensively in the BEIR Committee Report and by other 
groups that have to do with setting of standards. Physicians and 
others are admonished to keep radiation exposure to the fetus to a 
minimum, and actually the exposure standards for the fetus con- 
tained in the mother who is a radiation worker are more restric- 
tive than for the adults. 


Dr. Ellett. Is that true? I thought that this was not true. 

Dr. Bond. It is a recommendation -- it is a firm recommenda- 
tion of the NCRP. 

Dr. Ellett. The NRC did not change the recommendation. 

Dr. Morgan. Please speak into the microphone. 

Dr. Bond. Let me say that the recommended standards apply to 
the fetus, which of course, of necessity, applies to the mother. 

Dr. Morgan. Dr. Ellett, did you wish to comment? 

Dr. Ellett. Yes. 

We will get into this later, but it might help to clear 
things up a little bit now. 

When we say standards, we have to be careful about what we 
mean. Dr. Bond referred to recommendations from the NCRP. These 
are recommendations, not standards. They have not been implemen- 
ted by standard-setting agencies, that is as far as I know. 

Let us be careful today, because we are dealing essentially 
with a lay audience. In referring to a recommendation by NCRP -- 
let us say "recommendation." When we say "standard," let us re- 
fer to something that is law, i.e. legally binding. 

This is, in a sense, a governmental hearing to see how infor- 
mation can be used by the Congress. I would not like them to have 
a false impression that things exist that do not exist. 

Dr. Morgan. Dr. Mattson? 

Dr. Mattson. Dr. Morgan, one brief comment. 

Dr. Ellett properly said that the ICRP and the NCRP have made 
recommendations regarding the dose to the fetus being limited to 
some lower number than the occupational exposure limits for adults, 
since the increased radio-sensitivity of children which we are dis- 
cussing here today has been pretty well accepted by radio-biolo- 
gists for some years now. 

Present Federal radiation standards do not now contain such 
a provision. Such a provision was recommended by the Atomic Ener- 
gy Commission in January, 1975. It was put out for public comment 
at that time. 

In following through on that recommendation, the people I 
work for have issued a guide to females employed in the nuclear 
industry, the people that we license, telling them of this in- 
creased radio-sensitivity of the fetus should they become pregnant 
and advising them of the actions that are available to them under 

You can well imagine that there are other competing interests 
in this nation with respect to discrimination in employment of 


women, if there were different radiation standards, and with re- 
spect to invasion of privacy. There are several points of law 
that act very strongly in this field, one being the Supreme Court 
decision on abortion; the other being Title VII of the Civil Rights 
Act of 1964. 

Thank you. 

Dr. Morgan. Thank you. Dr. Mattson. Dr. Archer? 

Dr. Archer. I think we can summarize these special subgroups 
exposed to radiation fairly quickly. 

If we skip the entire population, who are exposed to back- 
ground radiation, ignore the exposure of everybody to radiation 
from nuclear reactors and a little bit of nuclear fall-out, we can 
summarize occupational exposures quickly. 

There are a number of occupational groups who are exposed to 
radiation, and in the past, there have been considerable numbers 
of over-exposures. These were mostly among medical radiologists, 
x-ray technicians, dentists, and dental technicians. There have 
been a number of studies showing excess cancer among these groups. 

But, with the advent of modern radiation protection tech- 
niques and controls, it is my feeling that few of them are being 
really overexposed any more. Uranium miners are another group 
that has been overexposed in the past; we now have an exposure 
standard for them which gives them substantial protection. I am 
not at all sure that the mine operators can reduce exposure much 
more than they have done. 

There is still some risk for uranium miners, I think, just 
as there is some risk in all radiation exposure. 

Luminescent dial painters are another exposed group. They 
formerly used radium for painting dials on watches, clocks, etc, 
and developed many bone cancers as a result. Introduction of good 
handling techniques and a switch to tritium has eliminated this 

In the practice of medicine in the past, some patients have 
been overexposed to radiation. The most noted ones are those who 
were injected with solutions of radium or thorium for various rea- 
sons. Thorotrast (containing thorium) was used as a medium for 
x-ray contrast. Those radioactive substances are not being used 
anymore. However, there are some physicians, especially dermatol- 
ogists, who use x-rays to treat some nonmalignant diseases. Such 
treatment sometimes results in worse disease than the patient ori- 
ginally had. 

It seems to me that this overexposure is unnecessary. In 
the past, some patients, like tuberculosis patients with gastro- 
intestinal symptoms, have received overexposure to x-rays. There 
is little overexposure now of tuberculosis patients. For some 
types of gastrointestinal symptoms, it is still standard to order 
a gastrointestinal series of x-rays periodically. That has be- 
come unnecessary now in many cases because there are better tech- 


niques for investigating disorders of the esophagus, stomach, duo- 
denum and colon. I am referring to the flexible fiberoptic endo- 
scopes. Workers in plants reprocessing uranium fuel are about the 
only persons in the nuclear industry who are likely to be current- 
ly overexposed. 

Dr. Morgan. For the record. Dr. Archer, I wonder if you 
would indicate to us how many cases of carcinoma among uranium mi- 
ners have occurred? 

Dr. Archer. I can tell you about our study group of uranium 
miners. 1/ We do not know how many uranium miners there are. We 
have estimated that there have been somewhere between 15,000 and 
20,000. We have about 4,000 of them in our study group. 

In the study group, there have now been 170 lung cancers. 
Over half of those are of the small -cell undifferentiated type. 
This type is much more frequent among uranium miners than other 

Mr. Goodman. I would like to ask if any studies are being 
made of the populations in the vicinity of the mill tailings? 

Dr. Burr. Offhand, I do not know of any. 

Mr. Goodman. May I recommend such? 

Dr. Burr. You may. We have had studies in some of the high 
background areas in South America. We have not been able to do 
studies in comparable areas in India. India has been doing studies 

Mr. Goodman. If we may return to the United States -- 

Dr. Burr. We are continuing studies of uranium miners. I 
did not mention this. 

This work now is devoted more towards studies of sputum cy- 

Mr. Goodman. Some fifteen years ago, Schubert and Lapp re- 
ported in their book some 5,000 low-level plutonium exposures at 

Is anything being done, epidemiological ly, about those work- 

Dr. Burr. The Transuranium Registry involves the plutonium 
workers. This is the study that has been going on a number of 
years and is a follow-up study, and does involve the Hanford work- 

I mentioned that more recently we have initiated, at the Los 
Alamos Laboratory, an epidemiological study of the plutonium work- 
ers that will be more extensive. 

The answer to your question is yes. 

Dr. Morgan. Are there any further questions? 


Thank you very much. 

Was there anybody else from ERDA? 

Dr. Burr. May I say a word? We have not had studies of pop- 
ulations in the vicinity of mill tailings. We have certainly had 
a lot of work assessing the various mill tailing sites and there 
has been a study at Grand Junction -- 

Mr. Goodman. I made recommendations about that in '65 that 
were totally ignored. 

Dr. Ellett. The Registry has come up several times today. I 
understand the participation in this is voluntary. I have no idea 
what kind of voluntary compliance you have with this. Is it 10 
percent of the workers involved, or 1 percent? 

The figures I saw were quite low. 

Dr. Burr. I would like to pass that question on to Dr. Marks. 
Would you come to the microphone and comment on this matter, Dr. 

I introduced him before as a pathologist. He is also the co- 
ordinator for our Human Studies. 

Dr. Marks. The level of participation varies greatly from 
one facility to another. The representation is very high in the 
Hanford plant and lower at other plants. 

Dr. Ellett. Could you give us the number, sir? 

Dr. Marks. At Hanford, of 2367 employees identified as trans- 
uranium workers, the Registry obtained releases for access to the 
employees' health physics and medical records on 2174. 

They have obtained agreements from 525 of that number in ad- 
vance of their deaths to have autopsies performed on them at death. 
The problem with autopsy permissions is that this is a very sensi- 
tive subject and necessarily voluntary. Many people have a pre- 
judice against making arrangements in advance to have autopsies 
performed after their deaths. 

At Los Alamos, health physics and medical record releases 
have been obtained for 259 workers, and autopsy permits obtained 
on about half of those. 

At Rocky Flats, 1772 transuranium workers are identified. 
There are record releases on 1611 of those and advance autopsy 
agreements on 173. 

Dr. Ellett. Could you give us Savannah River? 

Dr. Marks. Savannah River formerly were not participating 
in the program. The Savannah River plant is now an active parti- 
cipant in the Registry, but we do not have figures on the current 
status of enrollment of the plant employees in the Registry. 

Does that answer your question? 


Dr. Morgan. Thank you. Dr. Bross, I believe perhaps you 
could direct most of your response to the special groups where 
there are concurrent insults and the effects that may suggest 
some synergism between these relationships? 

Dr. Bross. I think that all of us are exposed to x-rays 
or other radiation from various sources. I think the problem 
is cumulative genetic degradation rather than a single exposure 
-- as that you have mentioned. 

The problem is really more difficult than is recognized be- 
cause in addition to people who are obviously exposed there are 
other groups in the population that have unusually high risk. 
For example, patients who go to a physician who practices defen- 
sive medicine and uses x-rays against malpractice. Or young wo- 
men under 50 who have enrolled in a radiological surveillance 
program which is intended to reduce the deaths from breast can- 
cer, but (in this group under 50) may have just the opposite ef- 

Then there are patients who go from one doctor to another 
with obscure maladies and get a whole new series every time, be- 
cause there is very little provision for transfer of information, 
and so on. These are groups which are difficult to protect un- 
less you deal with the whole problem of controlling the sources 
of radiation that are being given to the population. To con- 
clude, I would just like to mention one problem: It is so easy 
to overlook one group of risks when you are concerned with an- 

We had talked here about the protection of pregnant women 
in the NRC proposals. For the benefit of the group, there are 
instructions to the persons who are in a managerial capacity to, 
essentially, give a warning. The statement concludes that you 
have to take risks. You should protect yourself against this, 
just as you should not smoke, nor climb stairs during pregnancy. 

In focusing on pregnant women, for example, the directive 
ignores the fact that women who are not pregnant can also be ex- 
posed to radiation. They will also have, in their children, a 
markedly increased risk of leukemia. There is also, of course, 
the question of whether the pregnancies are known or not. 

The problem is not as simple as it might look, and it real- 
ly requires some persons or groups who would have a direct mis- 
sion for this purpose. 

Dr. Morgan, Dr. Shleien? 

Dr. Shleien. Just some comments on what has been said in 
the last few moments, in an attempt to distill some of the 
thoughts in the statements. 

Everyone is in agreement that unnecessary radiation should 
certainly be avoided. In speaking about particular groups that 
have been mentioned, the Bureau of Radiological Health of the 
FDA is carrying out some investigations relative to those you 
have mentioned. 


79-767 O - 76 - 5 

For example, the treatment of benign diseases with radia- 
tion, a practice which has been decreasing, is now under invest- 
igation, under contract with the Bureau at the Nation Academy of 

The problem of mammography screening has also come to the 
attention of the Bureau of Radiological Health, and its Medical 
Radiation Advisory Committee has issued recommendations with 
which we generally are in agreement. 

Dr. Morgan. Would you state the recommendations for the 
record, please? 

Dr. Shleien. The recommendations are: 

"Women of all ages should receive annual physical 
examinations of the breast and be taught breast 
self-examination. For asymptomatic women the 
first, or baseline, mammographic examination 
should be performed between the ages of 35 and 40. 
A second mammographic examination should be per- 
formed in 3 to 5 years unless indications of in- 
creased natural breast cancer risk for an indivi- 
dual warrant more frequent examinations. Subse- 
quent mammographic examination of women who re- 
main asymptomatic should depend upon reevaluation 
of the patient's personal risk status, the current 
understanding about the efficacy of mammography, 
and evaluation of radiation risks. After age 50, 
annual or other regular-interval mammographic ex- 
aminations should be performed." 

Dr. Bross. May I say one thing on that? 

I agree with the recommendations, but the programs are not 
operating this way. 

Dr. Shleien. I do not understand that. 

Dr. Bross. The NCI, the National Cancer Institute, has 
screening programs that do not operate according to those guide- 
1 ines. 

Dr. Morgan. Dr. Caldicott? 

Dr. Caldicott. Being a clinician, I feel that we do prac- 
tice defensive medicine and that we take x-rays in case we might 
be sued sometimes; we take x-rays without thinking of performing, 
sometimes, an adequate clinical examination and x-rays are not 
monitored as to dose, particularly in the pediatric field. Some 
children have packets and packets of x-rays, dose of x-ray and 
radiation on each x-ray is not recorded and therefore we do not 
know the amount of radiation that these children have had. 

I think this is very important, not only may it be a risk 
for those children later -- later in life. You must not forget 
it takes from five to fifty or forty-five years for a cancer to 
develop. Those children may live long enough to develop their 
cancers . 


It may also affect those children's gonads, once again, the 
testes and the ovaries. 

The fact that was pointed out about fertile women in indus- 
try also applies to fertile men in industry. I have here a paper 
on thirty autopsies that were performed by the U.S. Transuranium 
Registry. This is a registry that registers all men -- I guess 
they are mostly men who have worked in the transuranium industry 
for the last 30 years, 20,000 workers. This is the first report 
of the first 30 autopsies of these people. 

Eleven out of thirty died of cancer, which is an incidence 
of 37 percent. The normal incidence in the population of cancer 
in an autopsy population is 17 percent. 

Three others died of suicide, and two of suspected suicide, 
and almost all the rest died of arteriosclerosis of some form or 
another and Dr. Martell has reported that arteriosclerosis may 
be related to the deposition of alpha emitting particles within 
the blood vessels. 

This is hard data that actually workers in the transuranium 
industry are dying from results of radiation. 

Dr. Morgan. Could this report of these toxic cases be pro- 
vided for the record? 

Dr. Caldicott. Yes. 

Dr. Morgan. Dr. Archer? 

Dr. Archer. I have read that report which just has been 
mentioned, and as an epidemiologist, I felt I could not make any- 
thing out of it without knowing the age distribution of the pop- 
ulation that one is dealing with. You cannot very well say what 
the ratio between cancer and other diseases should be, even what 
the causes of death might be, unless one knows the age distribu- 
tion of the group. 

Dr. Morgan. Dr. Richmond? 

Dr, Richmond. I would like to suggest that perhaps some of 
that information may be made available for the record of the 
hearing, because that is not, as I recall, the conclusion of the 

Dr. Caldicott. We do have the age distribution. 

Dr. Archer. Pardon me, perhaps I did not make my point 
clear. One has to know the distribution of the population from 
which the deaths are drawn, not just the ages of the persons who 

Dr. Richmond. I would like to make a general comment, too. 
We may be missing our responsibility to convey basic information 
to the audience. 

We have a very varied, I am sure, group of people here. One, 


I think we have to be very careful to state, where we are talking 
about generalizations. We have been talking about the effects of 
radiation on the developing embryo. This has been taught in reg- 
ular biology classes, general classes, for decades. It is common 
knowl edge. 

It is also common knowledge that the same biological causes 
for the increased sensitivity also make the developing embryo 
sensitive to many biological insulting agents. 

It is not unique to radiation, I would like to make that 
point clear. 

Two additional points: One, we have been aware of this. It 
is factored into the standards. It is a generalization, a biolog- 
ical generalization. 

I would also like to call attention to the fact that we 
should not overlook the obvious, that is, if you are born today, 
your lifespan is decades longer than people who were born earlier 
in this century. Also, the statistics are at hand to show that 
there have been dramatic changes for the better in infant mortal- 

I suggest we do not cloud the issues with too many techni- 
cal details and avoid the obvious things, that we have to be sure 
the public understands. 

Dr. Morgan. Mr. Barnett? 

Mr. Barnett. Since we are still talking about population 
groups which need extra protection because of extreme vulnerabil- 
ity to radiation, we should not exclude the embryo and the fetus. 

In this connection, our Bureau has a project at the Massa- 
chusetts General Hospital which is testing the feasibility and 
effectiveness of requiring that referral slips for abdominal 
x-ray examinations of young women indicate the pregnancy status 
of the patient. It will be interesting to see if this pilot stu- 
dy results in a lower number of these examinations being ordered, 
and perhaps an increase in the number of pregnancy tests as well. 

One more comment on this type of protection. We feel it is 
very important to educate the patient to volunteer information 
about pregnancy to the clinician. One of the most important 
things the patient can tell the physican is, "Doctor, I think I 
may be pregnant." This will affect his decisions, not only 
about the ordering of x-ray examinations, but also drugs that 
may affect the fetus as well. 

Dr. Morgan. Dr. Bertell? 

Dr. Bertell. There are several things that have been inti- 
mated, for example that some of the problems of the past are no 
longer with us, and one of these problems is the radium dial 
painters. In a booklet from the Bureau of Radiological Health, 
it is estimated that these dial workers receive 12.1 rads per 
year -- external, whole body dose of radiation .2^/ 


It was a tragic situation. Yet, if you look at the present 
regulations for workers in the industry, while they are generally 
under 5 rad, there are exceptions where they can go to as much 
as 12 rad a year. It is permitted under certain extenuating cir- 

I would just point out that this 12 rad permitted, on occa- 
sion for nuclear workers is exactly the same exposure which was 
so tragic in the radium dial workers. 

Dr. Ellett. Could you straighten us out on the difference 
between rads and rems? The radium workers were getting some- 
thing like 12 rems, or 12 rads? 

Dr. Morgan. I am not sure what the estimate of rad or rem 
was to radium workers. I think it was in the neighborhood of 12 
rem per year. 

Dr. Bertell. Yes, for external gamma radiation, the rad and 
rem are essentially the same. It is the external radiation in 
the nuclear industry, which can go up to 12 rad, that is compar- 
able to the 12 rem the radium dial workers received. 

Dr. Ellett. The radium worker with internal alpha? 

Dr. Bertell. Rem-wise it is the same, 12 rem. 

Dr. Ellett. I thought doses for radium workers were in 
terms of rem, were largely the same as at the start of their ex- 
posure, and 12 rad radium alpha is 120 rem, not 12 rem. 

Dr. Morgan. Mr. Jablon had a comment in reference to the 
BEIR Report. 

Mr. Jablon. There seems to be some question about just what 
the effective doses were in the radium dial painters, and the 
BEIR Report quotes Rowland's studies as follows: "No sarcomas or 
carcinomas have been seen below the total accumulated mean bone 
dose of 500 rads,"!/ and I would remind you that for an alpha em- 
itter, 500 rads would be the equivalent of 5000 rems. 

Dr. Bertell. For the sake of clearing the r^^cord, concern- 
ing our previous discussion of the radium dial workers, I would 
like to point out that my first statement referred to a yearly 
exposure and I compared it to a yearly exposure of a worker in a 
nuclear plant. 

I think when Mr. Jablon responded, he talked in terms of a 
cumulative dose over a number of years, and I think it should be 
very clear that we were talking about two different measures. 

Dr. Morgan. Are there any other comments? Dr. Sternglass? 

Dr. Sternglass. I would like to add that it is widely be- 
lieved that only a fraction of a millirem is the dose to the pub- 
lic from nuclear plants, I have here in front of me the New York 
State Health Department report entitled, "Environmental Radiation 
Effects of Nuclear Facilities in New York State,"!/ in which, for 


Indian Point Station, Unit 1, the annual average dose in milli- 
rems, due to halogens and particulates alone for 1972 is given at 
62 millirems at the boundary, and there are many other plants 
that have levels on the order of 10, to 20, to 30 to 50 millirems 
just due to the halogens alone. 

Therefore, we cannot assume safely that when the plants are 
such that everybody will be living within 50 or 60 miles of two 
of them that the doses will be a tiny fraction of a millirem. 

Dr. Morgan. We will take questions from the audience. Pleas 
identify yourself, if you wish to make a comment. 

Mr. Kepford. I am Chauncy Kepford. I live in York, Pennsyl 
vania . 

It has been stated there have not been controlled human ex- 
periments with controlled radiation exposure. I disagree. There 
are thousands of workers who have worked in the plutonium indus- 
try. There was an entire division of U.S. Army troops that 
marched off across radioactive ground immediately after an atom 
bomb test in 1954 or '55. 

Where are the health records of all these people? 

Have they been followed up? 

In the industry today, if one looks at the old Atomic Energy 
Commission Reports of worker exposure, at least numbers 1, 2, 4, 
5, and 6, the years 1968 through 1973, one finds a radically in- 
creasing incidence of worker exposure and overexposure to radia- 
tion. That is about 5 rem per year. 

My question is, where are these follow-ups? The fact that 
we have film badges that record exposure is one thing. Unless 
the health data of these people that have been exposed to radia- 
tion are followed, there seems to be very little need whatsoever 
to record their exposure in the first place. 

Dr. Morgan. Dr. Burr, perhaps you would give a very quick 

Dr. Burr. I would just comment that we do have studies of 
the health and mortality of workers. I will touch on this later 
when I talk about some of the programs that ERDA has. We have 
tried to take advantage of the information that is available. 

There are other studies among which the Transuranium Regis- 
try has been mentioned. This is a follow-up of plutonium workers 
I will touch on that briefly, too. 

That is probably sufficient for now. 

Dr. Morgan. Dr. Bertell? 

Dr. Bertell. Maybe Dr. Burr could answer this. If you are 
not collecting data on chronic diseases, what do you expect to 
see when you analyze the data on exposure? Is there any place at 


all in industry where the medical record of the employee shows 
the medical history of offspring, so that, should there be gene- 
tic damage which shows up in the offspring, it will be noted? Is 
any industry recording this so that it can be analyzed? 

Dr. Burr. To take your second question first, T do not be- 
lieve so. There are, of course, genetic studies associated with 
the studies in Japan, and these include studies of the F-1 gener- 
ation, but to my knowledge I am not sure there is anything that 
would be comparable to what you have in mind. 

The first question was on chronic diseases. Some informa- 
tion of this nature is obtainable from the health and mortality 
studies, I do not say it is available in an analyzed form at the 
present time. 

Dr. Morgan. Yes Ma'am? 

Ms. Villastrigo. My name is Villastrigo. I am with the Wo- 
men's Strike for Peace. Dr. Caldicott made a very important 
statement here that I think the panel should deal with a little 
bit more carefully in the next few hours. She said we are enter- 
ing into a Plutonium economy that has only just begun. 

One of the problems with the plutonium economy that has not 
been dealt with is in areas where weapons production is going on 
today in many parts of the country. People around those areas 
are being exposed to radiation, including the testing areas like 
Nevada. I would particularly point to the Rocky Flats area where 
many people have been recently exposed to the very plutonium 
economy we are talking about. 

Rodger Rappaport in his book, "The Great American Bomb Ma- 
chine," published some time ago, has dealt with this issue of the 
weapons producing areas where it is absolutely dangerous to live 
because of low level radiation. 

I would like to know whether any studies have been made with 
regard to the people who live in those areas and the levels of 
radiation that those people are being exposed to and whether we 
can ever get any kind of information about that? 

Dr. Morgan. Does the panel care to respond? 

Dr. Ellett. I will respond in part. 

EPA is doing a special study for Rocky Flats, looking at 
plutonium samples. They are also looking very carefully at cat- 
tle who are slaughtered. They feel that cattle will have much 
higher doses that people since they are putting their breathing 
apparatus much closer to the ground. We hope from this study to 
get some kind of information that is based on more than data on 
the air around Rocky Flats and find what is getting into humans 
and animals in that area. 

Dr. Morgan. The gentleman in the yellow coat? 

Mr. Swann. My name is Mark Swann. I live near some nuclear 


plants in Pennsylvania. 

I am wondering whether it is feasible to have small epide- 
miological studies made around individual plant sitings. It seems 
that we would not be involved with large programs and in the 
event of accidents, small accidents, I am assuming, we would be 
able to measure where we started from. 

It seems to me if we spend money on trying to figure out the 
mechanism of the radiation injuries and the damage we will just 
waste time, and we should try to find out what kinds of things 
are happening. 

I assume you would have to have a test area also. 

Would it be fair to have the cost of such a program at least 
shared by the nuclear interest who, after all, are making money 
out of the enterprise? 

I would like Dr. Bross to answer. 

Dr. Morgan. We have on our panel some of the country's lead- 
ing epidemiologists. I will give only one of you an opportunity 
to respond. 

Dr. Bross. This is a feasible study and we have tried re- 
peatedly to set it up in one place or another, including York and 
other places. 

There is a great interest in talking about these things. 
When it comes to doing them, and more particularly funding them, 
there is a sudden diminishment of this kind of interest. 

You have heard of the very large sums of money that are go- 
ing into a reactor program, breeder reactor program, and other 
programs including high energy physics programs. For a very small 
amount of that money you could run one of these health surveil- 
lance systems, but nobody is interested. 

Dr. Morgan. Dr. Collins, representing the labor union, I 
would like to call on him to make a statement. 

Dr. Collins. We have been hearing a lot about cost benefits. 
We have radiation standards for workers which are considerably 
higher than for the general public. 

As I sit here today, I have a feeling of disquiet at 5 rem 
per year upper limit. The members of the Oil, Chemical and Atom- 
ic Workers, many of them workers in the nuclear fuel cycle, have 
also a feeling of disquiet which they have made evident to us. 

The National Resources Defense Council last September filed 
a petition that the occupational exposure limit be reduced by 
tenfold to .5 of a rem per year for workers under 45 years of age. 
At that time, our union supported their petition. 

At the present time, I would like to reiterate the position 
of our union that the limit for whole body radiation should be set 


by NRC at 0.5 of a rem in any year, 0.3 of a rem in any quarter, 
and (age - 18)x0.5 rem for a long time accumulation. 

The National Council for Radiological Protection, in noting 
the enormous susceptibility of pregnant women to radiation, re- 
commended that only half of 1 rem in any year be given to a preg- 
nant woman. 

Of course, under present standards she may very well receive 
considerably more than that before she even knows she is pregnant. 
At that time, the proposal to extend the NRC recommendation for 
pregnant females, the NRC expressed it was unwilling to make a 
special case for pregnant women on the grounds that it would be 
sex discrimination, the right to privacy and depriving them of 
the right to work. 

The proposal, is that we extend the standard for pregnant 
women to all workers. We agree with NRC that in terms of admin- 
istering a plant, it would be very difficult to make a special 
case for one particular class of workers. The reduction of radi- 
ation exposure limits should be extended to all. 

Our union is also very concerned about the internal emitter 
problem. The very fact that alpha radiation is shortrange makes 
it very dangerous inside the body. It has a radiological, bio- 
logical effectiveness (RBE) of 10 and its short range leads to 
heavy radiation of the body cells adjacent to the emitter. 

Pure alpha emitters are very difficult to detect outside of 
the body. The inaccuracy of bioassay monitoring is conceded by 
everybody whose papers I have read. 

We need tightened standards of airborne radiation. 

Our union has no immediate proposal, but is studying air- 
borne radiation hazards with the purpose of preparing definite 
recommendations for new standards. 

Dr. Morgan. Thank you. 

y Archer, V.E., Gillam, J.D., and J.K. Wagoner. Respiratory 
Disease Mortality among Uranium Miners. Annals of the New 
York Academy of Sciences, v. 271. 1976:280-293. 

2/ Mogliss, A. A. and M.W. Carter. Public Health Implications of 
Radio-Luminous Materials. Bureau of Radiological Health. 
Food and Drug Administration. Rockville, Maryland. July 
1975. (DHEW-FDA-76-8001). 

y Committee on the Biological Effects of Ionizing Radiation, 
National Academy of Sciences. The Effects on Populations of 
Law Levels of Ionizing Radiation. Washington, D.C. N.A.S. 
November, 1972. p. 132. 

4/ Terpilak, Michael S., and B.L. Jorgensen, Environmental Radi- 
ation Effects of nuclear facilities in New York State: v. 15, 
no. 7, Radiation Data and Reports. EPA, July 1974:375-400. 


Chapter VI 

Federal and State Responsibilities in Regulation. 
Monitoring and Inspection 

Ad equacy of Present Monitoring Programs 

Dr. Morgan. Let us go on to the next question, question num- 
ber five. What is the responsibility of the Federal and state 
government for protecting the public and those various subgroups 
from harmful amounts of radiation? Who is responsible for moni- 
toring and inspecting the major emitters of low-level ionizing 
radiation, and is this monitoring adequate? 

Dr. Shleien? 

Dr. Shleien. The Bureau of Radiological Health of the FDA 
has the responsibility for the control and monitoring of electron- 
ic products that emit radiation. This responsibility is defined 
in Public Law 90-602. Although the Bureau is responsible for 
various types of radiation, this conference is limited to ioniz- 
ing radiation. 

Some of the standards that the Bureau has issued are: A 
performance standard for diagnostic x-ray systems and their major 
components; a standard for television receivers; a standard for 
gas discharge cathode ray tubes; a performance standard for cabi- 
net x-ray systems, including x-ray baggage inspection systems. 

In addition to the issuance of standards, we also collect 
and monitor information relative to medical radiation dose. Most 
of the medical radiation dose information presently available has 
been from the Bureau. Two programs in this area are being car- 
ried out. 

One was the exposure to x-rays in the U.S. population, the 
XES study!/; the other program is the NEXT study (National Expo- 
sure to X-Ray Trends). This system monitors the means and the 
extremes of x-ray doses from specific x-ray procedures. 

In addition, we have a large research program involved in 
the study of radiation bioeffects. 

Some of the projects that we have supported under this are 
the Alice Stewart study in fetal exposure. There is the largest 
ongoing long-term exposure study on beagle dogs being performed 
at Colorado State. The tinea-capita studies^./, particularly the 
one carried out in Israel, is a large population and is an at- 
tempt to extend the curve for dose response to lower dose levels. 
Linked to this study is one in animals to determine the relative 
carcinogenicity of radio-iodines versus external radiation. 

The last aspect of our program that I would like to mention 
is one dealing with improvement of radiation practices. I think 
that I will leave that to Mark. 

Mr. Barnett. Bernie mentioned one of the responsibilities 
at the Federal level is to set standards for and monitor the per- 


formance of machines that produce radiation. Complementing that 
are our programs to improve the individuals who use those ma- 
chines, upgrading the practices of physicians, radiologic tech- 
nologists and dental personnel who apply x-rays to humans. These 
programs are essentially educational in nature. 

For example, we have developed a learning system for medical 
students and residents in radiology which teaches them the basic 
principles of radiation practice and which is now being used in 
approximately one-third of U.S. medical schools. 

Likewise, we have a training program for x-ray technicians 
that is used in almost half of the 1100 or so x-ray technology 
schools in the country. 

We also have the responsibility to set guidelines or recom- 
mendations which are gradually being published in the Federal 
Register on good x-ray practices, including the use of gonad 
shielding to protect patients from the genetic effects which were 
alluded to earlier in the discussions. 

We have recommendations underway on such issues as the irra- 
diation of pregnant women from diagnostic x-ray examinations and 
the use of quality assurance programs at medical facilities to 
assure the best possible radiographs with the lowest possible 
patient exposure. 

We also have a responsibility to educate consumers about 
medical x-ray protection. Again, our programs to educate both 
health professionals and consumers are complimentary to our pro- 
gram of setting standards for and monitoring the performance of 

Dr. Morgan. I would like to ask the question, when can the 
Bureau of Radiological Health assure us that all the x-ray tech- 
nologists are educated, trained and certified in the use of x-ray 
equipment and there is similar knowledge and educational require- 
ments of the medical doctor who prescribes these x-rays? 

Mr. Barnett. We feel the improvement is taking place with 
respect to the knowledge of the individuals who use radiation. 
It is true that we presently lack uniform criteria for educating 
and assigning credentials to either individuals who prescribe or 
apply radiation to people, and some sort of consistent credential 
standards are probably needed. 

Several states now that license radiologic technologists, 
use regulations that are often not compatible with each other, so 
there is a need for uniformity there, too. 

Dr. Morgan. I have been prodding the Bureau for years to 
get on with this. Perhaps our next speaker from the Bureau will 
indicate this job is underway, or maybe EPA will get on the job. 

Dr. Ellett. I will get to that on your time, not mine. I 
would like to respond to the listed question which is, what is 
the responsibility of the Federal -state governments in the pro- 
tection of the public from radiation. 



I have looked at this. To some degree, it is very much a 
mixed bag on who has the responsibility for what. I think the 
public needs a greater understanding of what the responsibilities 

I will start with the EPA responsibilities EPA inherited, 
under a Presidential reorganization plan that set up EPA, the re- 
sponsibilities of the Federal Radiation Council. I think the 
Federal Radiation Council's responsibilities have been somewhat 
misunderstood. Everybody says that their standards follow those 
of the FRC. Well, FRC did not establish standards. FRC provided 
guides to Federal agencies. They defined guides as a radiation 
dose that should not be exceeded without careful consideration 
for the reasons for doing so. 

That maybe sounds strange now, but in the context of 1960, 
when this was prepared, it was in a different era and I do not 
think that it was particularly poor guidance at that time. There 
may be some question of whether it needs updating or not. I am 
not prepared to respond to that right now. 

The FRC also recommended that all exposures always be ac- 
companied by a benefit and that all exposures should be con- 
trolled so as to be as low as practical. I think that most of 
the arguments that are being made today on radiation standards 
are not on the question of what the basic guides are or how basic 
standards are established (by other agencies and by EPA), but 
whether these standards call for doses that are truly as low as 
practical . 

To continue with what EPA's responsibilities are, under the 
plan that set up EPA, they were given the responsibility for set- 
ting both levels of radioactivity (quantities and concentrations) 
and doses in the general environment. This standard setting 
authority was created under the Atomic Energy Act and applies on- 
ly to materials covered under that act. We believe where these 
responsibilities come from (their legal basis) is very important 
to what a Federal agency does. EPA can also set standards in 
special situations like for drinking water. That responsibility 
was assigned by Congress. In general, however, EPA has not set 
radiation standards, rather it provides guidance to other Federal 
agencies . 

Radiation standards are set by other regulatory agencies, 
such as the NRC which provides standards for licensed material, 
materials produced in atomic energy reactors, etc., that make 
materials defined by the Atomic Energy Act. 

ERDA is not thought of as a standard-setting organization, 
but I assume they set as many standards as anyone in the country. 
They set standards for all of their contractors. This is essen- 
tially a part of their contracts. 

ERDA has books of regulations that are known as their manual 
chapters for radiation standards. This controls what the expo- 
sures are for a large fraction of the occupational field. These 
standards are within the FRC guides. 

When we get down to state governments, the state situation 


seems to be somewhat less clear. It looks as if states have some 
responsibility for setting the level of exposure standards for 
radioactivity, but one interpretation of the Minnesota decision 
by the Supreme Court, in which the Supreme Court did not review 
the appeal court's decision, was that the states were pre-empted 
from saying anything about radiation hazards from materials cov- 
ered under the Atomic Energy Act ( Northern State Power Company v, 
Minnesota ) . 

Control of natural radioactivity is the responsibility of the 
states. In the past there has been a reluctance, perhaps, on the 
part of the Federal government to look closely at hazards from 
natural radioactivity. The only Federal guidance out is on radon 
exposures to workers in underground uranium mines. 

There was a second part of this question, who is responsible 
for monitoring and inspecting the major emitters of low-level 
radiation? Is this monitoring adequate? It asks for various 
agency representatives to describe the number of persons and bud- 
get devoted to these responsibi 1 ites 

EPA has the responsibility, that was transferred by law from 
the Public Health Service by Executive Order to collate, analyze 
and interpret data on environmental radiation levels. We obtain 
the data from NRC and from ERDA that they receive from their mon- 
itoring programs, which I am sure they will describe to you. 

We have some information from the states published by EPA. 
EPA also has its own monitoring network called the Environmental 
Radiation Ambient Monitoring System and it performs work in its 
laboratories for the states and for its own special projects on 
what environmental levels are. 

This is not a large program, but it is a major program in 
terms of EPA radiation funds. Our '77 budget calls for 40 posi- 
tions being devoted to this type of monitoring, collation and 
publishing of the information on background radiation and $760,000. 
This is roughly a quarter of our total budget for radiation in the 
the agency. 

Of the $760,000, about $350,000 is for our environmental 
monitoring system which, by the way, is not at every reactor but 
it is in places in the general environment. We usually pick sam- 
pling stations so they are fairly close to some nuclear facility, 
but the system covers large metropolitan areas as well, and other 
selected places, so we have a large geographical distribution. 

We also are doing about $500,000 worth of special field stu- 
dies this year. This program is concerned with places where an 
environmental problem has been identified. 

We are also spending $225,000 on monitoring of non-ionizing 
radiation. This is the only Federal program for non-ionizing rad- 
iation regulation in the country. I will not go into details of 
our program. 

Dr. Morgan. The last part of the question was, is this ade- 
quate? Do you need more money in EPA, or is this an adequate pro- 


Dr. Ellett. I am not in the position to discuss adminis- 
trative budgets. I think, really, the panel and the public have 
to decide what is adequate and what is not adequate. We have 
twenty active stations to sample radioactivity in air at the 
present time; another fifty-four on inactive status. 

We have twenty stations in the country that look for pluto- 
nium and uranium particles in the air. We have twelve that look 
for krypton. 

We sample a grand total of fifty-five surface water sources 
and seventy-six drinking water sources, and, in conjunction with 
the states, we also look at the interstate carrier systems, water 
supply to trains and things like that, up to a level of two hun- 
dred samples per year. It does not seem like an overwhelming pro- 

Dr. Morgan. I dare say some of the panelists later will 
have some opinion on whether it is adequate. 

We have now heard from the Bureau and the Environmental Pro- 
tection Agency. We will now hear from NRC. 

Dr. Mattson? 

Dr. Mattson. NRC gets its authority for regulation from 
three basic places, the Atomic Energy Act of 1954, the National 
Environmental Policy Act of 1969 and the Energy Reorganization 
Act of 1974. Our responsibilities are very broad and quite 
unique, I think, in Federal Regulation, as to the detailed 
authority granted to us in controlling the users of source mater- 
ial, byproduct material, and special nuclear material, as they 
were defined in the Atomic Energy Act. These responsibilities 
include the safety of facilities handling these materials, the 
exposure of the public for normal operation of these facilites, 
the exposure of workers within these facilities, the use of by- 
product and special nuclear materials as radioisotopes in nu- 
clear medicines and industrial applications. 

Because our authorities are rather broad with these three 
types of materials, we also run into interfaces with other ag- 
encies. In that regard, we have consistent regulations with 
the Occupational Safety and Health Administration of the Depart- 
ment of Labor, the radioactive materials transportation functions 
within the Department of Transportation, the Food and Drug Admin- 
istration, the people seated on my left, the Environmental Pro- 
tection Agency, and the United States military. 

Of most importance to today's discussion is our responsi- 
bility in regulating the nuclear fuel cycle, the production of 
electricity from uranium. The lines of responsibility there 
are very clear. As soon as uranium ore leaves the mine it comes 
under our regulations and stays there, right through its use, 
its reprocessing, and its disposal as waste. 

We have regulatory responsibility for the material from the 
time it leaves the mine. 

Some of our responsibilities have been delegated to the 


states under an agreement states program spoken of in our regula- 
tions. Approximately half the states in the United States parti- 

The kinds of authority that are delegated are those pertain- 
ing only to byproduct materials and source materials of less than 
a critical mass. Special nuclear material is kept for Federal 

These regulatory authorities go to the states, when a pro- 
gram proposed by a state is approved by NRC. One of the base re- 
quirements of those programs is that they have compatibility 
with the Federal regulations. 

As has already been said, there is pre-emption by the Fed- 
eral government of radiation standards setting for byproduct, 
source, and special nuclear material. 

Now as to how our system works. Basically, our system of 
regulation is divided into four functional areas. We write stan- 
dards in the form of regulations. Title 10 of the Code of Fed- 
eral Regulations contains NRC regulations. 

We license individual facilities as they fall under these 
regulations. We do a case-by-case review for each new reactor, 
processing plant, uranium mill, whatever. 

We inspect the operation of those facilities against li- 
censed conditions which are specified as a matter of contract, 
if you will, with the Federal government. "Contract" is not the 
right word; I should explain that. 

License conditions are a matter of law, i.e., enforceable 
under law, within those license conditions are contained the pri- 
mary requirements for monitoring by our licensees. That is, 
rather than the Federal government monitoring each facility case- 
by-case, we require as a matter of license, for each facility, 
that the licensee do the monitoring. We require effluent moni- 
toring, environmental monitoring, and monitoring of the people 
who work in the facility. All of this monitoring is specified 
along stringent lines contained in our regulations. 

In addition, we inspect the operation of each facility 
against its license conditions to see that the licensee is doing 
the monitoring. In addition we audit in the sense of independent 
measurements to confirm licensee measurements. Not at all facil- 
ities all of the time, but as a sort of spot check. 

Our success with monitoring has been very good. I might 
note that there have been a number of states who have become in- 
volved in third-party monitoring, if you will, in addition to 
the licensees and the NRC. States have said they want to keep 
track of the emissions from various fuel cycle facilities. We 
encourage that, in fact, we have a program for some partial 
funding of that through the Federal government. 

It has worked very well in the past, it goes back some 
twenty-five years, way back to Shippingport . 


As a summary on the budget question that has been raised, 
we have, in fiscal '76, some 2,200 people in the Nuclear Regula- 
tory Commission with a budget of $218 million this year, 

I did leave out a functional category in that regard, con- 
firmatory research. We do some research at NRC of a confirmatory 
nature . 

Unless there are further questions on the budget, I would 
just as soon leave it at that. 

Dr. Morgan. Do you consider that your program is adequate? 
Dr. Mattson. For now, yes, sir. 
Dr. Morgan. Dr. Caldicott? 

Dr. Caldicott. As a pediatrician, and if we proceed with 
nuclear power as it seems that most people around this table 
think is a good idea, can you guarantee that in a hundred years 
or 500 years the standards that you are talking about now will 
be conformed to, both in America and throughout the world, be- 
cause I do not come from America? 

Dr. Mattson. The operating life of the facilities we are 
licensing with this particular standard is over 30 years. You 
are talking about waste management, is that what your concern is? 

Dr. Caldicott. Waste management from breeder reactors. 

Dr. Mattson. We have no standards for the licensing of 
breeder reactors at the moment. 

Dr. Caldicott. Are we going to have standards of radiation 
acceptable to the population when breeder reactors come into be- 

Dr. Mattson. I do not believe we have licensed a breeder 
reactor yet. 

Dr. Caldicott. Are we planning to 

Dr. Mattson. There is one that has applied for a license. 
Yes, ma'am. 

Dr. Caldicott. Are we planning to go ahead with the breeder 
reactor program? 

Dr. Mattson. I think we talked about that this morning and 
the role of NRC in that regard to make independent judgments re- 
garding the safety and environmental impact of reactors for which 
people file an application. That is quite a different question 
than are we going ahead with the breeder reactor program. 

Dr. Morgan. Dr. Bross. 

Dr. Bross. I would like to start with the statement which 
was made by Dr. Mattson and others, in which he said, in effect, 
there is no human data on the low-level effects, genetic effects. 


We have a Tri -state Survey and we have information and the 
results in the children of their various health hazards. In this 
connection, I might add parenthetically, in connection with EPA's 
comment, following up this particular group would almost be a di- 
rect answer to the specific kind of study it asks for. 

The point is, if the members of the regulatory agency sit- 
ting here before you are going to say, there is no data -- this 
is not a question of science, it is a question of fact: is there 
data or no data? 

There is in our files, in our records, material in comput- 
able, usable form. It is a matter of fact, whether there is data 
on this or not. There is data. What we have here is a simple 
refusal on the part of the regulatory agencies to look at the 
data, to think about the data, to use this data. I publicly chal- 
lenge the NRC to set up an adversary science hearing, I will come 
down to argue this point. They can present any experts they wish 
against me or against our side. We will thrash out whether or 
not we can show clear-cut genetic effects from low-level radiation 
on the order of 1 rad. 

We will carry on this debate so members of the public can 
understand what we are talking about, not esoterical ly . 

Now I think, if we don't use the data we have, it does not 
really do much good to set up an elaborate system for collecting 
data. I have been in public health for 25 years, all the way 
back to the smoking and lung cancer issue. It was always: We 
need more data. We don't do anything about cigarettes. We are 
going to get more data. 

I do not think this is the way to solve the problem. I do 
not think obscuring the issues by bringing in cost factors and 
making a big mess of things is helping, either. 

There are human beings exposed to risk. The question is: 
Are they going to have diseases, are they going to die, as a 
result of this kind of exposure? 

That is the issue. It does not involve a lot of costs. The 
question is: Are there a lot of people who are going to get 
killed? If so, we do not want to do it. 

Let me say that I strongly support a program for getting 
better data and I think this has come up several times for low- 
level radiation hazards. 

I support it with the intent that it is going to be used to 
do something about these hazards and not as a method of simply 
delaying public action. We know what to do right now. 


Dr. Morgan. Dr. Mattson, you have been thrown the glove. 
Will it be pistols, or will it be swords? Do you care to re- 


79-767 O - 76 - 6 

Dr. Mattson. First of all, I do not think I said that there 
were not any human data. I think that the conclusions drawn from 
the data were not hard evidence of a direct link between low-lev- 
el radiation and health effects in man. We have heard people 
discuss both sides of that issue all day today. 

I assure you, Dr. Bross, you need not throw down a gauntlet 
to have an ear in my office. 

Dr. Morgan. He has suggested that there be a public hearing. 
Maybe you might consider that also. 

Dr. Mattson. There are procedures for obtaining formal hear- 
ings by the NRC. I am sure you are aware of them. They are called 
Petitions for Rule-Making and Requests for a Hearing. I certain- 
ly, as an individual, am not empowered to grant such a request on 
behalf of the Commission. 

I repeat, my telephone line is open, my door is open. If you 
want to discuss this subject, bring in the data. We are there to 
1 isten. 

Dr. Morgan. Dr. Burr? 

Dr. Burr. I am Dr. Burr from ERDA. I will comment briefly, 
because ERDA's role has been touched on already. 

ERDA does retain the responsibility for its contractors and 
our environmental monitoring budget for ERDA contract operations 
is approximately $6 million a year. This involves about 450 people, 
including both ERDA and contract personnel. 

The data is gathered, reviewed and published. Dr. Burr has 
a set of information from the recent environmental monitoring pro- 
gram that we would like to leave with the committee. 

Dr. Morgan. Thank you. Dr. Burr. Dr. Burr, we will receive 
it. We will now hear from Dr. Archer in reference to NIOSH. 

Dr. Archer. The major governmental agencies dealing with 
radiation have already been heard from. There are three others 
that have some concern. 

One is the Mine Enforcement and Safety Administration -- 
MESA. The other two are the twin agencies created under the Oc- 
cupational Safety and Health Act. They are the National Insti- 
tute for Occupational Safety and Health and the Occupational 
Safety and Health Administration, NIOSH and OSHA. 

MESA, the Mine Enforcement Safety Administration, gets their 
authority from a special metal mine act which gives them author- 
ity to control all hazards in mine operations. It is mines they 
are concerned with, and they have a very active program for mea- 
suring the concentrations of radioactive material in essentially 
all mining operations. They concentrate on radon daughters in un- 
derground mines. 

The law which created NIOSH and OSHA has provided very wide 


powers for these two agencies: for NIOSH to investigate prob- 
lems and OSHA to enforce standards. They have very wide powers 
to look into and control occupational hazards. However, the law 
also puts in an exception, it excepts those situations where au- 
thority has been delegated to other agencies. 

In this case, nearly all of the authority for radiation pro- 
tection has been delegated to other agencies; both NIOSH and OSHA 
are concerned very little with it. The one study that NIOSH re- 
tained was the study of uranium miners. We retain this for his- 
torical reasons. The Public Health Service got into that study 
at a time when none of the other agencies were interested in it. 

Thank you. 

Dr. Morgan. Thank you. Dr. Bertell? 

Dr. Bertell. I think we are talking here about protecting 
the health of the public and when I think about protecting the 
health of the public, the first thing I wondered about is how 
healthy are the people? 

I look back at the OSHA form which has to be filled out by 
employers. If you have an occupational ly-related illness, you 
have to report this at least in the state of Vermont within 72 
hours. Unless you received more than a 50 rad dose and got im- 
mediately sick from radiation, that is, within 72 hours, there 
is no obligation to report radiation-related disease. 

I read Dr. Lassiter's report^/ -- he is from OSHA. He gave 
this report at a meeting of the New York Academy of Sciences in 
March 1975. He said the OSHA reporting form from employers picks 
up 2 percent of the medically-diagnosed, occupational ly-rel ated 
disease, 2 percent. This is not watching people. This is not 
seeing what is happening to the people in the occupational situ- 

Reports in industry need to be kept only five years. Again, 
you have eliminated a whole slew of diseases. 

You do not have a cumulative record that moves with the 
worker. If he changes employment, he starts all over again. 

We say we are very interested in people exposed to medical 
radiation. We have done several extensive studies on the doctor, 
the physician radiologist. Dr. Vilma Hunt_/points out that no 
studies have been done on women who are the x-ray technologists. 
We brought up Women's Lib a few minutes ago. 

I think there is something radically wrong with a monitoring 
program when we do not look at the people and say, are they sick? 

I just finished reading a report on the uranium mineworkers. 
It says in this group of 25 there were no cases of lung cancer. 
They told you nothing else about the people, are they sick, what 
is the matter with them, have they died of anything? 

I just think that the important issues are being lost in a 
whole lot of paperwork. 


Dr. Morgan. Thank you. I think it is very important to 

have this on record. Certainly, many of us have been made aware 

of this statute of limitations for example, it does not provide 
adequate protection. Dr. Richmond? 

Dr. Richmond. I would like to respond to that last comment 
that was made. I believe you meant plutonium workers, not uran- 
ium workers . 

Dr. Bertell . Yes. 

Dr. Richmond. I know of at least three places where that 
information is published, including the open literature and the 
details are given as to the causes of death. 

I would like to also mention that that particular group of 
individuals was studied since 1944, during the war years when 
the first nuclear weapons were developed. These people were stu- 
died and they are still being studied today. 

For the record, this is a published, scientifically reviewed 
document. Available evidence -- I encourage you to read it. 

Dr. Bertell. Could I have the reference? 

Dr. Richmond. I think I have a copy with me. I will give 
it to you personally. 

Dr. Bertell. Thank you. 

Dr. Morgan. Could you provide this for the record also? 
Dr. Richmond. I would be very pleased to. (See Appendix) 
Dr. Morgan. Dr. Mattson? 

Dr. Mattson. May I interject briefly on something Dr. Ber- 
tell said? 

It should be clear for the record that people who are ex- 
posed to radiation as a matter of their work are monitored with 
devices that measure radiation. We do not depend on workers re- 
porting to their management they have been sick. We require un- 
der law that they report exposure to radiation. 

I believe that is the case for other agencies as well. The 
2 percent does not apply to radiation. 

Dr. Bertell. Excuse me. There is a differnece between re- 
porting how much radiation you are exposed to and what diseases 
later occur, to see if there was a correlation. Those are two 
different questions. 

Dr. Morgan. Dr. Archer? 

Dr. Archer. Perhaps I could add a bit of clarification to 
this matter of reporting. 


A number of state occupational laws do have provisions for report 
ing diseases related to occupation. Most of the states have simi 
lar laws. 

But, as a rule, about the only conditions that are reported 
under these laws are accidents, because they are obviously rela- 
ted to work. Sometimes acute diseases, things that happen right 
on the job, are reported. Any chronic disease or long-delayed 
diseases are rarely or never reported. The primary reason for 
this is that nobody recognizes them as occupational disease. Even 
if a doctor thinks a chronic disease might be occupational ly re- 
lated, he cannot be sure of it. 

The only way that one can really be sure of the etiology of 
these diseases is through epidemiological studies. The method of 
reporting occupational disease for chronic or long-delayed dis- 
eases just does not seem to work. 

Dr. Morgan. Dr. Caldicott? 

Dr. Caldicott. Do any of those studies show people with ter 
minal diseases injected with plutonium? 

Dr. Mattson. May I respond to that? 

Dr. Morgan. Dr. Mattson? 

Dr. Mattson. People who work with radioactive materials 
such as plutonium which are dangerous as internal emitters are 
working in an environment where the routine operation is one of 
total confinement of those internal emitters. Only in unusual 
circumstance such as maintenance or accidents or incidents do 
the internal emitters become airborne within the working envi- 

When that happens, the workers put on respirators. They 
are monitored by health personnel very closely when that happens. 
For example, swabs of mucus, or internal measurements are made. 

Dr. Morgan. Dr. Caldicott? 

Dr. Caldicott. When you put people on respirators, it does 
not necessarily remove the plutonium particles nor the bronchial 
swabbing or bronchial lavage. It may remove some; it may not re- 
move all of it. 

I would like to address myself to the responsibility of the 
Federal and state governments for protecting the public. We are 
about to embark on, it seems a plutonium economy, not just now, 
but for future generations for hundreds of thousands of years. 

By the year 2020, we will have produced 30,000 tons of plu- 
tonium. There would be 100,000 shipments of plutonium per year 
on the highways of the United States, it is predicted. We know 
that plutonium is one of the most toxic, carcinogenic substances 
we have ever known, such that a millionth of a gram will produce 


I would suggest that the responsibility of the Federal and 
state government, is to work out regulations and reports right 
now, but we cannot predict what future generations and societies 
will do with this plutonium and what will happen to it, and what 
v/iU happen to future generations of children and also that 
is just the year 2020, what about the year 2050, what about the 
year 3000, if we keep on with nuclear power? 

I would suggest, as a pediatrician that this is the biggest 
public health hazard we have ever known, bigger than malaria and 
smallpox because the potential damage to the genetic building 
blocks of life is immense. 

I would suggest that the responsibility of the Federal and 
state governments is to stop producing nuclear power plants and 
plutonium now. We are already contaminated with plutonium, all 
of us, from fall-out. We do not know what the danger is yet. 

We need large epidemiological studies. We do not know of 

the dangers to other generations. Is it up to us to prove it 

is dangerous or for the industry that wants to proceed to prove 
that it is safe? 


Dr. Morgan. As Chairman, I would not ask the panel to re- 
spond to this. I am sure that it would take the rest of the 
week to adequately respond, but we have promised the audience 
that we would give them a chance to make a comment or ask a 


Mrs. Brackman. I am Selma Brackman, a coordinator for some 
sixty-odd peace organizations in the United States. The name of 
our coalition is the Coalition for International Cooperation and 

Over the last year, we have addressed ourselves to a peace 
ballot on which we have two propositions that will be afforded 
to every major candidate and one of them says that the United 
States should enact stringent legislation to prevent pollution 
of the oceans and the atmosphere, and the second is that sub- 
stantial public funds should be used to develop nonnuclear ener- 
gy, including solar and geothermal energy and where possible in 
cooperation with other nations. 

Now the question this morning was, how much authority should 
the states have as contrasted to the Government, the Federal Gov- 

As a coordinator for another coalition in Vermont, we found 
that Vermont is the first state in the United States to say to 
the Federal government, we reserve the right to veto the restric- 
tions or the permission that the Federal government has given for 
the siting of a new nuclear reactor. 


I know Vermont quite well, having lived there for a number 
of years during the summertime and the Yankee Vermont power re- 
actor has had numerous blasts, and some of the pontif ication that 
goes on at this table wherein some of the gentlemen state, we 
will not allow it -- well, it has been allowed. Not by you, not 
by me, not by anybody, but it just happens. 

These overdoses that come out, we do not know for ten or 
twenty or thirty or forty years what is going to happen to the 
people who live, what is going to happen to the workers there. 
None of this comes out in the newspapers. 

I think it is high time that some investigation to that ef- 
fect is made, that the very real problems that are not even ad- 
dressed here to the effect that the radiation problem occurs and 
there is nothing we can do after a certain point. 

We are not all omnipotent, and we must realize that. 

Dr. Morgan. Mr. Goodman. 

Mr. Goodman. It so happens that the Governor of Vermont 
asked me to come up and advise him about that plant when the ap- 
plication was first filed, and I told him in my judgment it was 
the wrong kind of plant and at the wrong place at the wrong time. 

It was the State of Vermont that passed the regulation to 
permit central Vermont to sell the bonds to proceed with the con- 
struction of the plant, so I say to you the responsibility is not 
just in the Federal government. 

Dr. Morgan. Thank you. Other comments? 

Mr. Laitner. My name is Scott Laitner. 

There has been an increasing number of statements suggesting 
that we do not know all that much about the effects of radiation, 
particularly at low-level doses and dose rates. It seems to be 
a case where the more we find out, the more kinds of cause and ef- 
fect relationships there seem to be. 

This raises a question, I think Dr. Morgan pointed it out 
very well. The object seems to be that we should allow minimum 
exposure to radiation regardless of the source. My question now 
becomes, Why is it, looking in terms of manmade radiation or man- 
produced radiation effects; Why is it we always seem to be look- 
ing at nuclear power as given, rather than determining how we can 
do without nuclear power, recognizing the potential dangers? 

Why is it that regulatory agencies always seem to accept 
these things as given, whether in terms of medicine, or in terms 
of power production, and then try to balance the cost-benefit ra- 

Dr. Morgan. We will assume that Dr. Mattson would feel 
that this has been answered or has been responded to frequently 
in the open literature. Do you have any further comments? 


Dr. Mattson. I would challenge that there is such an assump- 
tion by the Nuclear Regulatory Commission. NRC is an independent 
regulatory agency charged with licensing the use of byproducts, 
sources or special nuclear material. If there is no nuclear po- 
wer industry, we do not license anything. 

If people propose facilities, and they are safe, we license 


Dr. Morgan. The next person? 

Ms. Salzman. My name is Lorna Salzman, and I am Mid-Atlantic 
representative of Friends of the Earth. I have two brief ques- 
tions. The first is: Why is the assumption made, in setting 
radiation standards, that workers are not part of the public? 
Worker standards for radiation exposure are different from the 
public exposure standards. 

I assume the workers in the population do reproduce with non- 
workers, and that therefore the genetic risks to them from radia- 
tion would be reflected eventually in the population at large. 
This seems to be an inconsistency in the Federal standards and I 
would like to have an explanation. 

Second, if the risk is as minimal as you say, why are the new 
proposed EPA standards considerably higher for workers than the 
public? Why not make the standards for workers the same as for 
the public? 

Dr. Morgan. Dr. Richmond, would you respond? 

Dr. Richmond. I am not at all certain why you are directing 
the question to me. 

Ms. Salzman. Perhaps I am in error. I believe you are the 
one who played down the risk to workers. 

Dr. Ellett. I would like to respond to the EPA part of it. 

Dr. Richmond. I will answer the question, though. 

Dr. Morgan. Would you like to give a brief response? 

Dr, Richmond. Very briefly, yes. 

Especially in regard to the first question you asked, there 
is a difference purposefully built in the regulations and standards 
to make the distinction between the worker and the person in the 
general public because, as is true with any endeavor, there is 
some risk associated with any kind of employment. That is a well- 
known fact. 

There is a biological principle here: there is no such thing 
as a free lunch. Everything you do has a risk associated with it. 

The assumption is that the radiation dose associated with em- 
ployment is relatively higher than that which you would expect the 
general population to assume. There is also a statistical argument 


that the lowering of the standard by roughly a factor of 10 al- 
lows for differences in age, et cetera, in the general popula- 
tion, because the people who are employed are generally in bet- 
ter health and are given physical examinations. So that there 
is a reason, obviously, behind this. 

I hope you did not get the impression that I am minimizing 
risk from radiation. 

Ms. Salzman. I got that impression. 

Dr. Richmond. My feeling is that we have been extremely 
fortunate. In fact we realized that early in this century. Be- 
cause of things like the young ladies who painted the radium 
dial watches, these adverse effects were reported in the mid- 
1920's, decades before plutonium and actinides were discovered. 

We realized fully -- this was before my time, obviously -- 
that there are serious effects associated with radioactive ma- 
terials. I think that early perception of the danger has been 
one of the things that has kept the record extremely good be- 
cause there is no documented evidence of any plutonium occupa- 
tionally associated disease. 

Ms. Salzman. Would you say there is a gene flow between 
the workers in the industry and nonworkers? 

Dr. Richmond, I do not think that requires an answer. 

Dr. Morgan. Dr. Ellett, you had a response? 

Dr. Ellett. Could you reword your question? I think you 
have things upside down. When we are talking about the proposed 
EPA regulations, they are lower than that for occupational ex- 

Ms. Salzman. Not for reprocessing plants. 

I believe it is 75 millirems. Is that the dose for indi- 
vidual workers in reprocessing plants? 

Dr. Ellett. As far as I know, EPA has proposed no regu- 
lations for occupational exposures at all. They have proposed 
limits for people living in the vicinity of nuclear facilities, 
a uranium fuel cycle that would include reprocessing plants. 
These limits are quite a bit lower than the 500 mrem/y indivi- 
dual limits of 170 mrem/y limits for populations that we have 
been using so far. 

The reason that these are lower is that these are based 
on cost studies that show that these limits are practical. 

I do not want to leave the impression that EPA limits are 
higher. They are the lowest of any limits that have been pro- 
posed. I must point out that these are proposed limits, not 
Federal standards. 


Mr. Augustine. My name is Bob Augustine. I am the staff 
researcher for the National Intervenors. We are a coalition of 
1 56 citizens ' groups . 

There are a number of things that I am concerned about be- 
cause we have not dealt with them today. They come under the 
purview of this conference. 

First of all, in connection with the NRC standards, they 
apply only to what are called planned releases and not to un- 
planned releases, which are accidents and leaks. We do not know 
how many curies have been released in unplanned releases. If it 
has been anywhere near approaching the figures that have been 
released in planned releases, we have only been monitoring half 
of them. 

The licensee monitoring program, which is what the NRC 
has, was not any good at Kerr-McGee, not any good at Shipping- 
port, and its spotcheck program has not revealed these. What we 
are going to do about these, I do not know. 

Maybe one of the things we can do is improve the penalties. 
If you look at the penalties for breaking all of the rules, they 
are not sufficient deterrents for that kind of action. 

The NRC standards also do not take adequate account of the 
ability of animals and plants to reconcentrate the materials 
that are released in nuclear power plants. 

There have been studies done that show that these factors of 
reconcentration by animals and plants would be thousands of times, 
40,000 times more than the concentration in the water. 

These things are not taken into account in the setting of 
NRC standards. 

There is a little bit of study done on the cow-milk path- 
way and a couple of others, but there are literally thousands of 
pathways where nuclear emissions from nuclear plants can get into 
human bodies. With licensee facilities, the lack of health phy- 
sicists is a scandal. The inadequacy of the film badge program 
for protection of workers is another one. 

If you are a worker and you work near a pipe that has a 
crack in it and there is a stream of gamma radiation that does 
not hit you in the chest, the badge won't show it and you won't 
know until the cancer develops. 

When you talk about monitoring adequacy, what we need to 
know is what is being monitored and how extensively, how many 
monitors there are around each plant, and what do they monitor? 

We have to check on all of these things. What would the 
improvements in the monitoring system cost? Who would have to 
pay for them? 

Furthermore, I would like to know, since we have some FDA 
people here, if radioactive contamination of fish and other foods 


occurs, what confidence can we have that the FDA would be able 
to detect it? 

Dr. Morgan, I don't think we can answer all of these ques- 
tions. I will give Roger a minute to expound. 

Dr. Mattson. I will be brief and go through these. 

Planned and unplanned releases are all reported to the NRC. 

Mr. Augustine. They are not monitored. Unplanned releases 
occur where you do not have a monitor. 

Dr. Mattson. If it is a nonaccident situation or abnormal 
occurrence in the operation of the facility, that occurs through 
the same effluent stream that the planned release would occur. 
As for the unplanned release in the case of an accident, there 
are monitoring capabilities for that, emergency monitoring capa- 

As to the question of fines, I think that history shows in 
recent years the stiffer application of fines, perhaps somewhat 
differently by the Nuclear Regulatory Commission. I really was 
not prepared to address that today, and maybe there is some food 
for thought in what you say there. 

As to the question of reconcentration of radionuclides by 
the various pathways and fish, we do consider that. Those are 
considered in our calculation models. 

You mentioned thousands of pathways and we only treat two 
or three. You are basically right, but we treat more than two or 
three, that is an oversimplification. In order to choose the 
dominant pathways there have been literally thousands of path- 
ways studied by which radionuclides leave facilities and reach 
man . 

Some of the research ongoing at ERDA continues to address 
these. We have confirmatory research at NRC continuing to ad- 
dress these pathways. 

As to the lack of health physicists, we recently changed the 
regulatory guidance on the qualifications of health physicists on 
all operating facilities in the nuclear fuel cycle, in fact, all 
the licensed facilities under the NRC purview. 

Dr. Morgan. It is not just applied to power reactors? 
It applies to the reprocessing plants? 

Dr. Mattson. Yes, sir. 

As to film badging being inadequate -- maybe the Bureau of 
Radiological Health would like to chime in here. We are about 
to have a public meeting on film badge qualification testing, 
something that is needed to be done. 

People have seen the need for this for years. They have 


tried a number of routes. The most recent try was half a dozen 
years ago. The data are now conclusive. It is not working as 
well as people hoped it would. We are talking about indepen- 
dent qualification laboratories of some sort, working with BRH 
and the National Bureau of Standards. 

The things that you mentioned concerning monitoring, the 
radionuclides you talked about, are all monitored. I do not have 
them all written down here. I cannot repeat them. I recognized 
them as you read them. 

We have a definitive set of guidelines on environmental and 
effluent monitoring for nuclear power plants and a similar set of 
guidelines is under development for fuel cycle facilities. We do 
not now have an operating commercial reprocessing plant in this 
country, but we have recently changed our regulations with regard 
to the gathering of reporting and monitoring data for that kind of 
facility as well as other fuel cycle facilities, if that is the 
point you are making. 

Dr. Morgan. Another question. 

Ms. Allen. My name is Judy Allen from Virginia. 

I am particularly concerned with the shifting state and Fed- 
eral responsibility, what may be an illusion of protection. 

I would ask Dr. Mattson about the total care that you say is 
given in the nuclear fuel cycle. A Charlottesville Council -per- 
son wanted to inquire about transportation of nuclear waste and 
contacted the state of Virginia, and was told by the state of Vir- 
ginia that these waste transport vehicles were monitored by the 
NRC and monitored by DOT. 

We contacted NRC and were told that your responsibilities 
stop at the utility site border, that you no longer are respon- 
sible for that transportation, so there is no monitoring. 

In fact, at the Department of Transportation we were told 
that they set standards for the 30-foot drop container but that 
they also do not do monitoring. 

Could you give us some idea of the kind of protection that 
we are afforded in the transport period when the NRC and the DOT 
seem not to monitor, but the state seems to think they do? 

Dr. Morgan. Dr. Mattson? 

Dr. Mattson. The Department of Transportation is right. 
They do certify the container for transport and the criteria 
against which they certify it are contained in their regulations. 

The NRC is also right. Once it leaves the site boundary it 
is outside of our jurisdiction. But that does not mean that in 
between nobody is watching it. 

As far as the licensing of the facility, the applicant has 
to state to the NRC "this is how I am going to take care of my 


wastes, as they are generated year by year. We are going to ship 
them. I am going to send them down the following railroads, down 
the following highways, they will be received at the following 
reprocessing plants, and so on." 

That statement by a license applicant is reviewed by NRC 
from a safety and environmental standpoint. 

Dr. Morgan. Dr. Caldicott? 

Dr. Mattson. May I finish my answer? 

NRC's monitoring of that shipment would occur as the shipment 
left the facility, probably under license requirement on the own- 
er or operator of the facility and then monitoring would pick up 
again when it is received at another NRC licensed facility, which 
it always would be. 

Dr. Caldicott. Could I ask, I believe there have been three 
autopsy series in the transuranium workers. The first 30 have 
been reported; have the others been reported? If not, how could 
we obtain this information, because I do think it is relevant to 
the discussion. 

Dr. Burr. Dr. Marks, our pathologist, tells me 50 have been 

If you are interested in learning more about the others, of 
course, they will be reported. He might speak to you at the break, 
if you 1 i ke. 

Dr. Morgan. I will take just one more question from the 

Mr. Mi Herd. My name is William Mi Herd. I am from the 
Center for Science in the Public Interest. 

I do not know whether the questions this afternoon will oc- 
casion any further discussion of the hot particle controversy. If 
they don't, it would be very unfortunate to leave Dr. Richmond's 
remarks as the record of that controversy. 

In particular, I am referring to his characterization, for 
instance, of the Biophysical Society's comments on the NRDC's 
(Natural Resources Defense Council) position. 

The AEC and ERDA erroneously characterized the Biophysical 
Society as agreeing with their position that the standards should 
not be changed, whereas in fact only one of the six reviewers 
so stated in their comments. Four others agreed that the evi- 
dence is available that will lead to a lowering of the standards. 
Two of them actually said the standards should be lower. Two 
others made other estimates of the degree to which the standards 
should be lowered, agreeing only that the NRDC in asking for a 
reduction by 10^ may have been exaggerated. But one of their own 
estimates suggested a lowering of the standard by 10^. 


Nonetheless, I think that the discussion this morning is a 
gross mischaracterization of the state of the controversy. Since 
there are so many here, including Dr. Richmond, who are involved 
in this controversy, if that issue comes up again, I think it de- 
serves a much more thorough discussion. 

Dr. Morgan. In view of the lunch hour that already has 
passed, I would like to indicate that after lunch we are going 
to make some minor modifications in the order of questions, but 
certainly we will discuss the role of the independent scientific 
community and what recommendations are to be made that are speci- 
fic for Congressional hearings and for action. 


Dr. Morgan. It has been requested that we get back for a 
few moments to question 5 and focus particularly on the last part 
of that question. 

I directed it to one or two of the panelists. The question 
is, namely "Is this monitoring adequate?" 

Seymour, I am not sure that you responded to that. Do you 
feel that as far as the uranium mining and so on are concerned, 
is the monitoring adequate, are the funds adequate? 

Dr. Archer. Yes, I think the monitoring and the funds are 
adequate to control the situation reasonably. As far as uranium 
mining in particular is concerned, it is only recently that the 
standard has been fully enforced. We are gradually getting down 
to it. 

Now that it has reached, and it is kept reasonably well, I 
think that the risk in the future will be greatly reduced and 
probably less than the risk of cigarette smoking. 

Dr. Morgan. As far as the Bureau of Radiological Health is 
concerned, I believe its attention is directed more at the manu- 
facture of devices such as color television and so on. I believe 
I asked the question before. I will repeat: Do you feel that 
the monitoring of such devices is adequate from your point of 

Dr. Shleien. As you mentioned, we do have a compliance pro- 
gram. Under Public Law 90-602, that is an enforcement program. 
I think the question might relate more to the monitoring of doses 
of radiation during medical procedures. 

I have already mentioned some of our earlier programs, the 
x-ray exposure program where we initially evaluate the gonad 
dose. We are now in the process of evaluating bone marrow dose. 

In addition, we have a system of monitoring where the maj- 
ority of the states are now employing the system developed for 
specific examination. 

Dr. Morgan. Has the 1970 report officially come out yet? 


Dr. Shleien. The 1970 GSD report^^is completed and at the 
printer. The report on bone marrow doses^/ is in the process of 
being prepared. 

Dr. Morgan. Dr. Ellett, do you wish to comment on the ade- 
quacy of this program? 

Dr. Ellett. I believe I did previously. 

Dr. Morgan. You have already covered that pretty well. Dr. 
Mattson, did you want to make any other comments on the adequacy? 

Dr. Mattson. The people from BRH and EPA mentioned a long 
list of special studies concerning monitoring. There was some- 
thing I left out in response to this question this morning. I 
indicated this morning that for particular facilities each li- 
censee is required to carryout a rather extensive monitoring pro- 
gram for the plant, i.e., effluents from the plant and environ- 
mental levels outside the plant. 

In addition to that, there are specific studies of a generic 
nature which are done by the Nuclear Regulatory Commission. I 
have one under my wing at the moment on uranium ore dust in mills 
which is a modest study, about $50,000 a year, I think. 

I was not prepared today to list all such studies of that 
kind that are carried on by NRC from time to time. As particular 
questions are raised, or particular issues come into focus, there 
are a number of such studies done by our confirmatory research 
people or by our inspection and enforcement people or by the stan- 
dards development people that I represent. 

Dr. Morgan. Thank you. Dr. Sternglass? 

Dr. Sternglass. I would just like to take a couple of mo- 
ments to point out with regard to the question of adequacy of 
monitoring that I was shocked, and I believe you were too, by the 
evidence that emerged at the Shippingport hearings that everyone 
agreed that the knowledge of just exactly what came out was not 

The monitoring was, to say the least, extremely poorly done, 
and in some cases there were contradictions between reports of 
operators who claimed that gases were allowed to leak out without 
being adequately reported. 

There were claims that the plant had zero release. At the 
same time, other people found a sizable quantity of strontium 90 
around the plant and in the fish and in the milk around there, 
and this raised the whole question of the adequacy of the monitor- 
ing of our nuclear facilities. 

I believe that this is a very serious matter in the sense 
that people are talking about hundreds and hundreds of these 
plants with much closer distances to population centers and areas 
where milk, cheese and other food is produced and sent all over 
the country. 


If the monitoring is not improved, I think that we are in 
very serious trouble. 

Dr. Morgan. Thank you. Mr. Goodman? 

Mr. Goodman. I think the overall test is really what hap- 
pens to the human beings that are involved. 

For some period of time, over a twenty-year period I have 
made a study of accidents in the atomic industry, the releases of 
radiation exposure. I have offered in recent years on a number 
of occasions a list of 500 individuals who were exposed or sub- 
ject to radiation. I believe that there ought to be an epidemio- 
logical study of the health records of these 500 individuals. 

I do not know of any comparable study that has been made on 
an overall basis. The workers who work in the industry who have 
been exposed ought to be the subject of an adequate medical stu- 
dy and I have the names here. I entitled this list simply, "In- 
dividuals Involved." 

If any of you want a copy, I would be glad to supply it. 

Dr. Morgan. Would you furnish one for the record? 

Mr. Goodman. I shall. 

Dr. Morgan. Thank you. 

From my own experience working in national laboratories, I 
am under the impression that the monitoring and the care for the 
health and safety of the employees in the neighborhood is what I 
would term adequate. However, I believe that there have been 
some areas under the judisdiction of the Atomic Energy Commission 
and perhaps now, NRC, that miss the mark of meeting the standard 
that I would say is even minimum. 

I am thinking at the moment of the hearings last week, for 
example, on the Kerr-McGee Cimarron, Oklahoma plant. I feel very 
strongly that they broke all the rules of radiation safety. I 
feel the same way about the West Valley Plant, chemical repro- 
cessing plant in upper New York. I feel that even some of the 
nuclear power plants have not had something that would approach 
an ideal health-physics organization where you have personnel of 
sufficient qualifications in charge of the safety of personnel. 

I would be quick to say, however, that I think that the AEC 
and the NRC and ERDA compared to some other industries have done 
a remarkable job in keeping track of radiation risks. I only 
wish that the fossil fueled power plants industry would do a 
little bit as good with reference to the oxides of sulfur and 
nitrogen, hydrocarbons and other insults in the environment. 

I certainly argue, however, that there are some areas under 
the jurisdiction of NRC that can improve. 


Dr. Mattson. Dr. Morgan, may I respond to that? 
Dr. Morgan. Yes, Dr. Mattson. 

Dr. Mattson. I would like to say quickly, that the past re- 
cord of monitoring facilities and specifying what environmental 
data should be taken, what absolute data should be taken, or how 
absolute exposures are monitored and tracked has shown evidence 
of weaknesses in the system. 

I would like to call your attention to some recent changes 
in that regard, both in our regulations and in our regulatory 
guides, that speak to these problem areas and ask perhaps that 
you personally, at least, would reconsider some of those views 
in light of this very recent information. 

Dr. Morgan. I am not sure what you have in mind. The plant 
I refer to in Oklahoma is not in operation, but it seems that it 
took the NRC a long time for it not to be in operation. 

Dr. Mattson. I was referring, sir, to the more generic 
guidance on monitoring. I was not referring to the Kerr-McGee 
facility. I am sorry if I misspoke. 

Dr. Morgan. I see, I intended to compliment you when I in- 
dicated that in terms of radiation risks we have done a good job, 
if we make our comparison to the chemical industry and other haz- 
ards in the environment. I would, since you request me to do so, 
mention also that when Drs. Gofman and Tamplin, some years back, 
suggested the lowering of permissable levels of radiation expo- 
sure by an order of magnitude, you went them one better and low- 
ered them even more, in fact you lowered them by two orders of 
magnitude. I certainly compliment you and your predecessor, the 
Atomic Energy Commission that subscribes, not to some fixed level, 
but to exposures as low as practicable (ALAP) and as low as rea- 
sonably achievable (ALARA), but I think that we can still point 
to some operations that you should ride herd on more to improve 
your record and your image in the public eye. 

Dr. Bross? 

Dr. Bross. I believe that the public very often are given 
reassuring statements on monitoring. If the statements are true, 
they can be taken in a broad sense or a narrow sense. 

The statements on monitoring can be confined to the quality 
of physics involved in the monitoring process. However, if the 
monitoring is doing any good, it should be affecting death rates 
and doing something to protect the public. 

A monitoring system that may look good on paper may not, in 
fact, be worthwhile in practice. 

Every time you look at details on monitoring, you get a 
shock. In the effort I mentioned about mammography, there is 
an effort to take a look at what actually is being delivered to 
women who are getting mammography. It ranges all the way from 


79-767 O - 76 - 7 

300 rrillirems to d hundred times that. 

It is a staggering range. This is, in actual practice, a 
monitoring system that might be considered adequate in terms of 
its paper performance and structure and so forth, is one thing. 
But a monitoring system that is doing its job has to work in the 
field, and protect the field. 

This is what I think the real issue is here. 

Dr. Morgan. Dr. Caldicott? 

Dr. Caldicott. How can we insure that monitoring will be 
sufficient when, as I mentioned, by the year 2020 there would be 
100,000 shipments of plutonium on the highways of this country 
and if there are accidents, who is going to be around to monitor? 

What happens to the people who are exposed, where will the 
plutonium be dispersed, in the wind and so on? And what will 
happen to people exposed to this released plutonium over thou- 
snads of years, number one. 

Number two, I have here the statement by Hubbard, Briden- 
baugh, and Minor, GE engineers who resigned recently from the 
nuclear industry in California, they state, some of the design 
defects and deficiencies alone create safety hazards. This is 
within nuclear power plants throughout the United States. 

"For example, the possibility of failure of the Mark I sup- 
pression containments. But the one most important point, and 
the point that we want to emphasize to this committee, is the 
cumulative effect of all design defects and deficiencies in the 
design, construction and operation of nuclear power plants makes 
the nuclear power plant accident, in our opinion, a certain 
event. " 

The only question is when and where. These men were top 
people in the industry, for many years. I wonder what differ- 
ence monitoring will make then. 

Dr. Morgan. Dr. Mattson? 

Dr. Mattson. Mr. Chairman, I would just note that Dr. 
Caldicott is referring to the testimony of the three persons 
which was the subject of congressional hearings that were just 
concluded recently by the Joint Committee on Atomic Energy. I 
do not recall the chairman of the committee's precise words in 
summarizing those hearings but they were something to the ef- 
fect that he had heard the story from one side and he had heard 
it from the regulatory side. He said that he personally was con- 
vinced that the regulatory system was working properly. 

This is not in debate today. The three people from GE had 
nothing to say concerning this dialogue today on low-level radi- 
ation. We are talking about the narrow subject of monitoring as 
it applies to low-level radiation. 

If we get too far afield and start talking about accidents 


and what we do in low probability events of a high potential con- 
sequence, we will have to go back and revise everything that every- 
body said today. We intentionally restricted our earlier remarks 
to normal operation, routine things that hapoened with low level 

I think we ought to stick to the subject. 

!_/ Bureau of Radiological Heath. Food and Drug Administration. 
Population Exposures to X-Rays: United States, 1970. Washing- 
ton, D.C. Govt. Print. Off. Nov. 1973. (FDA-73-8047) . 

y Modan, B. et al . Radiation-Induced Head and Neck Tumours. 
Lancet, v. 50. n. 7852. Feb. 1974: 111-11^. 

y Lassiter. Laboratory Management Participation in Long Term 
Investigation of Man in Occupational Monitoring for Genetic 
Hazards Workshop. Annals of the New York Academy of Sciences. 
V. 269. March 1975: 43-45. 

4^/ Hunt, V.R. Occupational Health Problems of Pregnant Women. 
A Report and Recommendations for the Office of the Secretary 
of the Department of Health, Education and Welfare. Washing- 
ton, D.C. Govt. Print. Off. April 30, 1975. (FA-5304-75) . 

y Bureau of Radiological Health. Food and Drug Administration. 
Gonad Doses and Genetically Significant Dose from Diagnostic 
Radiology. United States. 1964-1970. Washington, D.C. 
Govt. Print. Off. April 1976. (DHEW-FDA-76-8034) . 

y Shleien, D.Tucker, T.T. and D.W. Johnson. Mean Active Bone 
Marrow Dose to the Adult Population of the United States 
from Diagnostic Radiology. Bureau of Radiological Health, 
(in progress) . 


Chapter VII 

Current Radiation Protection Standards. 
Responsibility and Scientific Casis 

Dr. Morgan. I believe we had better go on to question 6. Let 
me state the question, and I will take a crack at one of the ans- 
wers . 

Who must set the current radiation protection standards for 
public and occupational groups and what data are these standards 
based on? 

First of all, I would like to indicate that for many decades 
the National Council on Radiation Protection and Measurements 
(NCRP) and the International Commission on Radiological Protection 
(ICRP) have set what sometimes are referred to as standards for 
protection from ionizing radiation through their numerous publi- 
cations, but these, as has been indicated, are recommendations. I 
underline the word "recommendations." 

Although these are not laws or official regulations or codes 
of practice, they in fact serve in many instances the function of 
regulations and codes of practice. In many cases, for example, 
the regulations that exist, the codes of practice are based speci- 
fically on these recommendations. 

The first official guides at the Federal level in the United 
States, to my knowledge, were set by the Federal Radiation Coun- 
cil whose functions have now been taken over by the Environmental 
Protection Agency. There are many government agencies that have 
responsibility at the present time for setting radiation guides, 
standards, codes of practice, regulations. I might mention among 
others the former Atomic Energy Commission, now the NRC, the En- 
vironmental Protection Agency, the Bureau of Radiological Health, 
the Public Health Service, HEW, FDA, DOT (Department of Transpor- 
tation) , et cetera. 

And of course, each branch of the military has its own regu- 
lations and the states and a number of local governments have 
regulations to control and assure radiation protection and to 
set standards. 

And, addressing the second part of the question, by far the 
principal source of excessive and unnecessary population exposure 
is, in my opinion, medical and dental x-rays. With proper educa- 
tion and training, motivation, and certification, and with the 
use of improved equipment, I iDelieve that this exposure could be 
reduced to less than 10 percent of its present level. 

Even a 2 percent reduction in medical exposure would reduce 
population exposure more than could be brought about by completely 
eliminating the nuclear industry to the end of this century. The 
present radiation protection standards wherever possible are based 
on human experience -- the cause and effects of excessive exposure, 
most of which comes from excessive medical exposure. 

However, in many cases, essential data are missing. In such 
cases, one must rely on animal studies. The most important human 


data on which some of the present radiation protection standards 
depend are, for example, the human exposure history with radium 
that we have discussed and exposures of radiologists and other 
members of the medical professions to x-rays, studies of survivors 
of Hiroshima and Nagasaki atomic bombings, studies of medical pa- 
tients undergoing radiation therapy, and the studies of Alice 
Stewart and many others showing a large increase in incidence of 
leukemia, central nervous system tumors, etc. as a consequence of 
the use of diagnostic x-rays on pregnant women. 

I think again I might have encouraged some of you to respond 
to this question. 

Dr. Ellett. I think I probably see the question somewhat 
narrower than you do. As you pointed out, the NCRP in 1958 made 
recommendations for radiation standards. In 1960, the FRC put out 
guides that essentially affirmed NCRP recommendations. They were 
also confirmed by ICRP in 1959. 

If we have to say what data this is based on, we have to look 
at what data was available in 1959, not what data is available to- 
day. Recommendations, not standards particularly, have been re- 
viewed since that time. The current situation is perhaps somewhat 
different than it was in 1959. 

Certainly the occupational standard for radium was based on 
the industrial experience with radium workers and that is when 
there was a body of data available. As stated in the IRCP reports, 
nobody knew in 1959 if 5 rem per year was equivalent to the radium 
limits or not. I do not think that that sort of data became avail- 
able until the publication, really of the BEIR Report. They did 
have an inkling in 1959 that there was increased leukemia, perhaps 
from Hiroshima and Nagasaki data, although that was not at all 

If you go back to 1958 and 1959 when the recommendations were 
lowered to 0^ rem per year total for individuals in the general 
population, the main concern was genetic effects. People really 
started to believe that there was not a threshold dose, that there 
was harm as far as genetic effects were concerned. Almost no men- 
tion of cancer is made in the ICRP/NRCP study, but rather recog- 
nition that if you are going to expose large populations, you are 
going to have genetic effects and these effects are going to be 
with you, regardless of dose. 

As to the danger of cancer occurring in the general public, 
I do not think there was much concern expressed in the recommen- 
dations. As near as I can find out, the philosophy was that doses 
should be ten times less for people who were not occupational ly 
exposed. As the ICRP points out, we assume the occupational stan- 
dards for radiation place radiation workers under risks comparable 
to other occupational hazards in industry. There was a balancing 
of risk against risk, if you will, so that there would not be some- 
thing exceptional in the health effects observed in the radiation 
workers as long as their exposures were under NRCP/ICRP recommen- 
dations . 

When it came to the general population, I don't know whether 
it is fair to balance an occupational risk situation as against 


people who are not profiting by their employment and getting a 
radiation dose. The way NRCP and FRC have handled this is to say the 
risk should be somewhat less, that is a factor of 10 less. 

I don't know but that if we had a number system based on 20 
instead of 10 it would be a factor of 20 less, rather than 10. I 
have never seen a real rationale for what dose we allow for the 
general public. 

Dr. Morgan. I would take issue with some of the things you 
said. I was a member of NRCP and IRCP through all of these years 
and I was Chairman from the beginning of the Committee that pre- 
pared the internal dose report that you referred to. We did have 
access to some of the reports of the Hiroshima and Nagasaki survi- 
vors. We had access to some early data on the effects of exposure 
to the fetus, and we were particularly alerted to the human his- 
tory on radium exposures; so much so that our standard was the 0.1 
microcurie of radium in the body that corresponds to 30 rem per 
year. This was used in calculating the permissible dose for all 
the bone-seeking radionuclides. 

We did look very carefully at the history of the exposures of 
the radiologist. That basically is where our present figure of 15 
rem per year for most body organs came from. The British felt 
that the average exposure of early radiologists was of this order 
and that led us to have the two reference standards, namely 30 rem 
per year from radium 226 and 15 rem per year average exposure of 
the radiologist during the preceeding decades. 

So we did have a great deal of this data for our evaluation. 
I remember Dr. Muller, the geneticist, and I worked closely to- 
gether through these decades in preparing radiation exposure re- 
commendations. We had many arguments on whether the genetic risks 
or the somatic risks set the boundary conditions for radiation ex- 
posure levels. And so these discussions went on for a decade at 
least before the ICRP reports themselves came out in print. 
Dr. Bond? 

Dr. Bond. I should like to extend the remarks that you and 
Dr. Ellett made. I do not speak for the NCRP or the ICRP. With 
respect to the data, radiation standards have been based, histori- 
cally on findings of scientific committees of the NCRP and ICRP. 
These councils attempted to call upon the best talent available 
to help evaluate scientific data. 

In this country the NCRP has done this; in Britain, the MRC 
has done the same thing. At the time that fall-out was an issue, 
the British report was prepared and the so-called BEAR (Biological 
Effects of Atomic Radiations) Committee was preoared. This was in 
the middle 1950's. 

As far as I know, as alluded to, it was the report of the 
genetic effects part of the BEAR Committee that had a great deal 
to do with standard setting at that time (mid 50 's) and led 
fairly directly to the recommendation of the NCRP standard for 
the general public. In practice, this has been used very widely 
as the standard. It was the Genetics group of the BEAR Committee 
that stated, after a very careful review of the genetic effects 
data, the best available data at the time, that in their view, in 


order to get the jobs done 10 rems over 30 years might have to be 
"allowed" as an upper limit. That included medical x-ray expo- 
sures. This evolved into 5 rem over 30 years or 0.17 rem per year 
for the general public for all man-made exposure except medical. 

This was adopted as a recommendation for the general public 
and I would like to say that this committee stated very clearly 
what Karl Morgan also stated here -- that any numbers adopted as 
standards, are to be taken as upper limits, and that in fact the 
exposure should be kept to the lowest degree practicable. 

Obviously, these committees used the best data available at 
the time they met. Later committees have been appointed and the 
information has been updated. The main point is that the groups 
having to do with radiation standards have attempted to avail 
themselves of the best data and talent available. 

Dr. Morgan. Dr. Bertell. 

Dr. Bertell, If that recommendation was that they be exposed 
to no more than 10 rem in a generation, then there was another 
assumption implied, namely that 5 rem would come from medical, 
and therefore you could distribute the other 5 over industry, is 
that correct? 

Dr. Bond. Essentially correct, but not precisely. The pre- 
cise figure, I believe, was three or four, and the rest for atomic 
energy. That evolved into recommendations for other groups that 
there should be allowed an upper limit of 5 rem for the public, 
over 30 years, from all sources other than medical exposure. 

Dr. Bertell. There was an assumption there that we were getr 
ting about 5 anyway from medical sources, I think also in the 
beginning. Dr. Morgan, you said something about 73 millirads per 
year assumed medical exposure? 

Dr. Morgan. This figure is a result of the Bureau of Radio- 
logical Health studies. In 1969, their data were evaluated and 
they came forward with the number 73 rem per year to total body 
of the average person in the U.S. from medical exposure. 

Dr. Bertell. I would just like to give you the figures from 
the Tri-state survey on what people actually were getting on medi- 
cal x-ray. This is over a ten-year, approximately ten-year period 

Dr. Morgan. Excuse me, are these total body figures? 

Dr. Bertell. Total body for medical x-ray, and that includes 
dental. The male controls averaged 10.37 rads in a ten-year per- 
iod. The male cases 13.47 rads. Female controls, 11.7 rads and 
female cases 13.14 rads. 

If we are talking about 10 rads over a 30-year period, we are 
already over this limit when we just talk about medical x-rays. In 
the DHEW Report of 1970 on the exposure to medical x-rays in the 
United States, the estimate I could come up with, as an average 
per person, was 642 millirem per year external from medical x-rays 
not including dental . 


If you project that over a 30-year period, you are already up 
to 19.26. What we are saying here, even if you cut medical x-rays 
in half and take dental out, you are about at that 10 rem level 
over that 30-year period. 

Dr. Morgan. Thank you. Dr. Schleien? 

Dr. Shleien. We are talking doses to different organs. The 
standards are based on population doses, particularly genetic doses, 
over a 30-year period, and the latest reports on the genetically 
significant dose per capita, average significant dose, is 20 milli- 
rems in 1970. 

The 72 millirem figure was a mid-abdominal dose, really not 
a whole body exposure dose. The values you are quoting appear to 
be skin exposure so consequently we are talking about three or four 
different organ doses. 

I think the genetically significant dose is the dose referred 
to in the publication that Dr. Bond quoted in which 20 millirems 
was mentioned. 

Dr. Bertell. What about the 170 mrem? Is that not whole body 


Dr. Shleien. That excludes medical radiation. 

Dr. Bertell. It is whole body. Is it not external? Is it 
gonadal ? 

Dr. Shleien. Whole body or bone marrow dose per year. It 
is the absorbed dose, not exposure. Furthermore, the limits may 
be numerically equal but the doses to the organs may vary. This is 
whole body or gonadal. The limit works out to be the same. A 5 
rem gonadal dose over 30 years is 170 rems. A 0.5 rem whole body 
dose to an individual works out to be about 170 mrems per year for 
a suitable sample of the population. 

Dr. Bertell. That is a split-up of the 5 rem. It is not 
spread over -- 

Dr. Shleien. Exclusive of medical radiation. 

Dr. Bertell. I am trying to figure out why part of that, the 
5 rem you are telling me is gonadal if it has to do with medical 
x-ray, the other 5 rem is total body dose. 

Dr. Shleien. I was not saying that. I was saying that the 
present radiation standard excludes medical radiation. That is 
the first point. 

The second point that I was making is that the studies on 
which the standards were based included, when the calculations 
were made to evaluate the total dose, medical radiation. 

Finally the last number we have on the genetically signifi- 
cant dose is 20 millirem per year. The doses that you were quot- 
ing appear to be for individual procedures, and they appear to be 
skin exposures, not specific organ doses. 


Dr. Morgan. Dr. Bross? 

Dr. Bross. I originally had not intended to comment on this. 
I think maybe some of the audience is confused by the discussion 
here. I thought I would summarize it in my own way, by asking: 
What does this all indicate about the way standards are set? 

First of all, in case you did not get the message, the stan- 
dards are set on data that is ten or fifteen years out of date. In 
the second place, if you failed to get the message, the standards 
are set using methodologies such as linear extrapolation which are 
even longer out of date. 

The way in which the data arises is of interest, I think, for 
the group. How did we get this data that has been cited? The 
reason that we have data, for instance, on what happens to women 
when they get 200 rads delivered to their breast to deal with post- 
partem problems is because the radiologist thinks it is perfectly 
safe to do so. The radiologists give it, and ten or fifteen years 
later 15 percent of these women get breast cancer before they are 
50, then we know that there is a hazard. 

What I am talking about now is the general process, the pro- 
cess of setting standards. We set standards by obsolete methods. 

By the time we take any action on older hazards they have 
been replaced by new ones. This time lag results in our constant- 
ly, as far as our present population, being exposed to hazardous 

Dr. Morgan. Dr. Mattson? 

Dr. Mattson. Dr. Bross, I believe, gave his view before, but 
I think it contains a small confusion over the recommendations, 
standards and Federal regulations issue. 

It is true that the first recommendations on accpetable levels 
of radiation came out some years ago. It is also true that those 
recommendations have been reviewed by the recommending bodies many 
times since then on specific issues and general issues. There are 
many committees that continue to meet and consider these issues. 
They reaffirm their recommendations from time to time. 

Federal regulations concerning radioactivity, that derive in 
some large measure from these recommendations, change yearly. 

Our part 20 radiation standards, I would guess have changed 
on the order of five times a year, every year, since I have been 
faciliar with them. They change on small things, like signs 
used to control radioactivity or procedures used to work around 

As to the application of radiation protection principles to 
specific facilities, it is just not true that these things are 
fifteen years old and have not changed since. That is not the 
case; they are kept current with the evolving state of knowledge. 

Dr. Bross. I would like to ask: Specifically we have been 
talking about 5 rem standards, for instance. How long has that 
been in effect? on 

Dr. Mattson. That has been in effect a long time. It has 
been restudied many times. 

I can point to the ongoing EPA study of the 5 rem standard, 
if that is the one you refer to. 

Dr. Bross. What I would say is the study simply reaffirms 
the previous standard without bringing in the new evidence, which 
is exactly what has repeatedly happened, this is not updating it. 

Dr. Morgan. Dr. Sternglass? 

Dr. Sternglass. I want to say something exactly to this 

Much of the information that needs to be examined has simply 
only come about in the last three or four years. The last time 
that the BEIR Committee had a chance to examine this whole ques- 
tion at the request of the EPA was in 1970-71, and a lot of the 
data of Dr. Sanders at the low dose dates, the Rochester study 
on the dogs exposed to natural uranium, and the recent data from 
Dr. Petkau's studies on membranes of mice, altogether a tremen- 
dous amount of data, has simply only come during the last few 
years and it needs to be fed into the system. It looks to me as 
if when this is done, we will have to end up with some signifi- 
cant lowering of our permissible dose from environmental sources. 

Dr. Morgan. Dr. Richmond? 

Dr. Richmond. If you are interested in reading more recent 
related information, I might recommend NCRP-43, which is an up- 
date of the risk estimates.!/ 

Dr. Sternglass. It did not take these particular studies of 
membrane damage into account. 

Dr. Richmond. Let me comment. 

The National Council on Radiation Protection and Measurement 
is an organization of 70 individuals representing all sorts of 
disciplines, the medical profession, I think legal, but many. We 
have to assume that somebody, some group acts responsibly. They 
have a charter. There are similar international organizations. 

I do not know what more one can do. All you can do is say, 
well, they are not apparently using the information that an indi- 
vidual believes is very pertinent to the question. 

Dr. Sternglass. That is right. That is why, at the recent 
EPA hearings, I suggested that by law the EPA must take this kind 
of new information into account when there is no legal restraint 
on the NCRP or the ICRP or for anyone to take into account any 
particular data at all. 

But fortunately, under the National Environmental Protection 
Act, the EPA must, by law, take into account all the latest data 
and not select what it chooses to do in order to maintain an in- 
dustry in operation. 



Dr. Richmond. Your point is a good one. Let me caution 
against one thing. 

I think the words are "any reasonable" something or other. 
My point is that, I do not mean this in a derogatory sense at all, 
but a constructive sense, there are so many issues that beset us. 
How can we ever begin to act in depth on every one? 

We have to assume that there are bodies of experts who, in 
conjunction with regulatory agencies and public perceptions and 
public input, will make the right decisions. If you do not buy 
that, you do nto buy the way the system operates. 

Dr. Sternglass. I certainly buy the way the system operates, 
but the system will operate in the future under the inspection of 
the public in far greater detail than it did in the past. All 
these things were done in secret without anybody having access to 
any of the material on the basis of which the decisions were made. 

Dr. Morgan. Dr. Bond? 

Dr. Bond. Let me say again, that at the time the BEIR Com- 
mittee Report was organizing its activities, it let it be known 
far and wide that this activity was going on, and data from any 
individual or group was solicitied. All of the data submitted 
were considered, and considered in detail -- including the data 
submitted by Dr. Sternglass. All of the data were taken into 
consideration, to the degree that the committee thought they 
should be, in coming out with recommendations and conclusions. 

Dr. Morgan. Dr. Caldicott? 

Dr. Caldicott. If you thought plutonium actually does go to 
the gonads and there is data to show that it does, how do the re- 
gulating commissions in the government, therefore support an in- 
dustry which produces plutonium which will inevitably, at some 
stage or other, contaminate the gonads of individuals in this soc- 
iety and the world? 

We are not just talking about America; we are talking about 
proliferation of nuclear power plants throughout the world. 

Dr. Morgan. I think we had better go on to question 7. I 
do not think we can answer completely question 6 at this meeting. 
If we had a week to address it, I think we could do better. 

Dr. Ellett. I would like to say something in answer to a 
rather provocative statement that was just made. I think in this 
country. Congress has decided on what we are going to do about 
radiation. It is not the responsibility of the regulatory com- 
missions, as Roger Mattson pointed out, to turn the nuclear indus- 
try on or off. 

The plutonium decisions are being made pretty much by the 
money that is appropriated by Congress for the breeder reactor and 
I think it is misdirected energy, really to try to examine these 
programs in as narrow a context as what the health effects are. 


There are very big problems that have both costs and benefits 
associated with them. Just to hang on one point might be a 
rather narrow perspective. 

Mr. Goodman. The problem is that the agencies do not total- 
ly inform the Congress. I refer particularly to the suppressed, 
revised WASH 740 Report that had, in its initial draft, a much 
different conclusion than the agency has recently purchased from 

Therefore, it is impossible to rely upon the conclusions 
made by the Congress if the agencies are going to misinform the 
Congress . 

Dr. Morgan. Dr. Mattson? 

Dr. Mattson. The WASH 740 Report referred to is ten years 
old. It was done by an agency that does not exist anymore. 

I think we ought to get back to low-level radiation. 

Mr. Goodman. They were discussing low-level radiation, but 
the report, not being an acceptable version, was suppressed. 

1_/ U.S. National Council on Radiation Protection and Measurements. 
Review of the current state of radiation protection philosophy. 
Washington, D.C. Jan. 15, 1975. 50 p. (NCRP Report No. 43). 


Chapter VIII 

Health Effects of Radiation 
Is the Data Base Adequate for the Determination of Standards? 
What Research is Needed? 

Dr. Morgan. I think we had better go on to question 7. Let 
me read it and make a quick response. Is the data base on which 
these standards are based adequate to determine health effects? 
What areas of data collection and research need more attention 
and funding? 

Ironically, we probably know more about the harmful effects 
of ionizing radiation than about any other environmental agent. 
But the more we know, the more we need to know, because although 
the genetic risks of low-level exposure may be somewhat less than 
we considered them to be two decades ago, the somatic risks and 
in particular the risk of radiation-induced cancer of almost every 
type are more to an order of magnitude greater than we considered 
them to be sometime back. 

We very much need to have more research on low-level exposure 
to Plutonium and other transuranic elements. We need chronic ex- 
posure data on large animals and man, and microdosimetry on bone, 
lung and liver and of the effects over several decades of exposure 

We need more information on the environmental behavior of 
these elements and the migration in man's ecosystem. We very much 
need more information on the carcinogenicity of concurrent insults 
to man, for example, diabetes, respiratory diseases, smoking, ex- 
posure to SOx, NO^, hydrocarbons, food additives, drugs, radiation 

Let us have some responses to this question. Dr. Sternglass? 

Dr. Sternglass. I fully agree with the Chairman. I feel 

these are precisely the areas that now need attention, especially 

since we have learned that synergistic effects of the kind you 
mentioned are extremely important. 

We know, for instance, in the case of the uranium miners, if 
they first inhale pure radon gas and do not smoke, their rate of 
lung cancer increase is much less perhaps by ten or twenty times 
than if they also smoke, and it is precisely these kinds of in- 
vestigations at low dose rates, low dose effects by all types of 
ionizing radiation that we must find ways to encourage. 

If also means not only laboratory experiments on animals of 
the kind that Dr. Sanders and J.B. Little at Harvard are now do- 
ing in connection with the possibility that plutonium is an impor- 
tant factor in the health effects of smoking cigarettes, but it is 
necessary now to do the long-neglected studies of large popula- 
tions exposed to fall-out throughout the world, because these pop- 
ulations must now be examined with the most advanced statistical 
techniques, the best statistical techniques available. 

Since we have no other human exposure that is at this low 
level and in low dose-rate, the medical doses do not give us the 


same kinds of evidence; therefore, we need to undertake and fund 
studies of populations in different parts of the world exposed to 
different amounts of fall-out in time and in space. We need to 
do the same thing with populations living around nuclear facili^ 
ties that have now been in operation for more than thirty years. 
We must come to grips with what in some cases are, unfortunately, 
likely to be some very disturbing discoveries. 

But unless we ere willing to face the facts and do the stud- 
ies on fall-out, we are committing our society to a major source 
of energy that could produce an enormous increase in our somatic 
and genetic effects in the future. 

Dr. Morgan. Dr. Mattson, do you care to comment on this 

Dr. Mattson. I think I said earlier today that we are stay- 
ing in close cognizance of the ERDA research program on the effects 
of radiation. I believe that program has been on the order of 
$30 million to $40 million to $50 million, it fluctuates somewhat 
over time, in this general area for many years. I believe it is 
on the order of $45 million, as I understand it, in fiscal '76. 
That is all in the area of radiation hazards. 

We think that research program is aimed at the kinds of things 
that you spoke of. I think we generally agree with your broad 
categories of important areas of research. 

As far as NRC is concerned, we have no research at the moment 
in health effects, per se. That is, we have no direct research to 
determine what happens as a result of radiation exposure of humans. 

We do have in a broader context, though, quite a lot of effort 
being spent to study the movement of radionuclides in the environ- 
ment or in man. We also develop calculations or analysis methods 
for these kinds of things, including the controls of radionuclides 
in a facility such as the control technology for protecting workers 
and control technology for radioactive effluents. 

We also have modest efforts in research of monitoring tech- 
niques because the regulatory actions we have taken in recent years 
have pushed the state of the art a little bit on monitoring. We 
have had to do some confirmatory research to prove we could really 
monitor at the low levels we were requiring. 

Beyond that, I would make the general statement that the fed- 
eral research program, as we understand it, is generally on the 
right track and it is likely to yield answers to the questions that 
you spoke of in introducing this topic. 

Dr. Morgan. Dr. Shleien? 

Dr. Shleien. I would like to take the opportunity to mention 
some of the projects relative to bioeffects that the Bureau and EPA 
is presently engaged in. 

I think they relate generally to the discussion. One is the 
F-2 effects from x-rays on the human female fetus, specifically x- 
rays on pregnant women. 


The second is a study to determine the risk of thyroid tumor 
development associated with low-dose x-ray radiation. The Colorado 
State Univeristy study, which is a longterm study on beagle dogs, 
a very large study, on the ionizing effects of radiation when de- 
livered at various periods in development of the beagle. 

There is a National Academy of Sciences contract on an evalu- 
ation of the extent of the use of medical radiation in benign dis- 
ease. There are the studies undertaken by the Bureau itself in 
terms of relative carcinogenicity of Iodine 131 and external radi- 

Dr. Morgan. Mr. Barnett? 

Mr. Barnett. With respect to some of the information we still 
need in the medical radiation area, we would like to know more 
about the efficacy and in some instances the biological effects of 
potential x-ray substitutes, such as ultrasound. And with respect 
to some of the more traditionally conducted x-ray procedures we 
would like some information on the efficacy of these examinations 
when carried out in certain clinical circumstances, so that we can 
provide physicians with more concrete advice as when to order or 
not order a given x-ray procedure. 

Dr. Morgan. Dr. Bertell? 

Dr. Bertell. If we are talking about an adequate monitoring 
system, it is essential to talk about adequate monitoring of peo- 
ple. I would say that one of the sources of much of the disagree- 
ment on this nuclear question comes from inadequacy of the vital 
statistics to give us the information which we need about environ- 
mental pollution. 

This situation will exist until we are willing to redesign 
our vital statistics in such a way that they give us the informa- 
tion we need. It is not an esoteric question, it is something we 
know how to do and it could be done. 

Until we have a national data bank which gives us information 
on people who are exposed to radiation in their occupations, until 
this is no longer a split between GE, Westinghouse, Government fac- 
ilities, and so forth, until there is a standardized way to collect 
information on workers, until we collect it on the offspring of 
workers and have a national way to process this data, until we up- 
date the questions on vital statistics, our monitoring is inade- 

Dr. Morgan. Thank you. Dr. Bond? 

Dr. Bond. I would just like to make a comment without a judg- 
ment that monitoring of any environmental agent, any period, re- 
quires resources in terms of money and manpower. No one is against 
monitoring to any degreee commensurate with need and with resources, 
but I would say that there are many agents in the environment, many 
agents that are toxic. 

To monitor these things requires money and resources. In the 
overall question of degree of monitoring, this risk-balance equa- 


tion has to be addressed. We cannot look at radiation in iso- 
lation in this respect. 

Dr. Morgan. Dr. Bertell? 

Dr. Bertell. I agree totally that it has to address every 
environmental question, I would suggest that if we need money 
we use the money now being used to continue what I consider fruit- 
less research on the breeder reactor. 


Dr. Morgan. Mr. Jablon? 

Mr. Jablon. I would like, if I may, to tie these two remarks 
together. The speakers have come to a subject that is near and 
dear to my heart. The fact of the matter is that the vital statis- 
tics system in this country was built, I presume, for certain pur- 
poses, but it is a remarkably ineffective device for the research 
workers . 

In Japan, we have been able to prosecute a long-term follow- 
up study on 100,000 persons, survivors of the bomb, and this was 
possible only because the study could be based on the Japanese vi- 
tal statistics reporting system. It would not have been possible 
to mount such a study in this country. 

Not only for the sake of monitoring persons who had exposures 
to radiation, but as has been said, for other occupational hazards, 
for studies of health of all sorts, we have got somehow to struc- 
ture our vital statistics reporting system so that the kinds of 
studies that are needed can be done at a reasonable cost. For ten 
years, at least, there has been agitation in this country for some- 
thing called the National Death Index, so that if you are trying 
to follow a thousand people you would be able, in a simple way, to 
find who was alive and who was dead and what the dead person died 

We have made absolutely no progress at this time. There are 
a host of other things that could be done, but if we could get our 
vital statistics reporting system straightened out and amend the 
privacy act so that we can use the files, under suitable safe- 
guards, we can begin to make progress in some of these areas. 

Dr. Morgan. Thank you. Dr. Ellett? 

Dr. Ellett. First, as to whether or not the data base for 
radiation standards is adequate or not, let me say that the BEIR 
Report is a very adequate study. Perhaps it underestimates the 
risk in some cases and overestimates in others but I think it is 
a very good study, probably the best thing presently available 
on which to base public policy and decisions on radiation 

Frankly, my worry is that people will tinker inadvisably 
with the BEIR Report to make risks greater or less. EPA is 
having discussion with the Academy now about having the BEIR 


Report updated. There are questions that have come up, but I 
do not believe that BEIR Report numbers are going to change 
radically in the near future. 

In its consideration of radiation protection standards, 
the nation would be poorly advised to wait for more data. I 
think we have a good data base, certainly more than we have for 
any other pollutants. 

The second part of the question referred to what areas of 
data collection and research need more attention and funding. 
I think that the Federal establishment is particularly weak in 
doing epidemiological studies on radiation effects. I think 
we are weak in knowing what happens to children who have been 
exposed, in childhood - as they grow older, and also what is 
the ultimate fate of people who have been irradiated in utero. 
Nobody has been able to do a study to trace what happens to 
in utero exposed people when they reach the age of 40 - 50. 

This does not mean I accept the "new" information on 
health effects presented this morning and this afternoon. Very 
little of that information is really new and I disagree with 
almost all of the assertions made this morning concerning new 
and unexpected health effects. 

Dr. Morgan. Dr. Martell? 

Dr. Martell. I think there is one area in which the present 
standards are extremely poorly based, and that is with respect to 
the chronic effect of internal alpha emitters in soft tissue. This 
is a problem we have averaged away. The NCRP and ICRP have only 
talked in terms of average dose and average burden of internal 
alpha emitters. It was not observed that there were considerable 
differences in the physical and chemical properties of natural and 
pollutant radioactivity in soft tissue. Natural alpha radioacti- 
vity, radium, and polonium are soluble and uniformly distributed 
in the lung and in other soft tissue organs, unless thay have been 
converted by human activity into an insoluble particulate form. 
In the case of plutonium and other transuranium elements, the ox- 
ides are naturally in an insoluble particulate form. 

In studying the distribution of insoluble particles in man - 
not just plutonium but also insoluble particles that are present in 
cigarette smokers - the problem of internal alpha emitters as an 
agent of cancer in smokers has been ruled out because the total 
activity in the lung was only two or three times the natural alpha 
activity in the lung, but, in fact, as tumor sites insoluble alpha 
emitters in cigarette smoke are thousands of times higher than the 
natural alpha activity. The latter is distributed uniformly in 
soluble form. The insoluble particulates are highly localized in 
the bronchi . 


79-767 O - 76 - 8 

We are finding that here the residence time is of the order 
of six months. We have unpublished data to suggest that at other 
sites in the lung, it is much longer -- on the order of two years 
or more. 

On the basis of a two-mutation hypothesis: on the basis of 
local alpha doses which are thousands and tens of thousands of 
times higher than natural, we have, I think, good basis for sug- 
gesting that these insoluble alpha emitters may be a principal 
agent, the principal candidate agent of cancer in smokers. And 
we are talking about only a fraction of a picocurie at smokers' 
tumor sites -- not 16,000 picocuries (the MPLB for plutonium). 

This is an area where we seem to have a discrepancy about the 
significance of an organ burden by a factor of 10,000 or more. 

The two-mutation hypothesis is consistent with the age dis- 
tribution of cancer in the smoker and non-smoker groups. The act- 
ivity concentrations at the tumor site reinforce this possibility 
in terms of alpha radiation dose consideration. This hypothesis 
has been ignored by the NCRP, the ICRP and others responsible for 
radiation standards. I suggest that this is a hypothesis that can 
be tested and that it is time that we did so. Because if only 
fractions of a picocurie in human soft tissue organs can give rise 
to a significant, unacceptable tumor risk, why are we talking about 
proliferating alpha activity pollution with tons of plutonium and 
other alpha emitters. 

I suggest that this is one of the very serious questions that 
we had better address ourselves to, if there is to be any purpose 
to a meeting of this kind at all. 

Dr. Morgan. Thank you. 

Dr. Richmond. I want to make an observation at this point. 
I believe there are some areas that should be reinforced or im- 
proved in the general area of health protection and radiation bio- 
logy. I think this is true with almost any subject. I guess where 
I have my concern, is to look at all the so-called biological in- 
sulting agents that man is exposed to in his environment. This in- 
cludes many heavy metals, it includes all kinds of interesting or- 
ganics, pesticides, the list is huge. In fact, for those of you 
who are interested, there were some House Committee hearings held 
last year on the cost and health effects of low-level exposure to 
pollutants, including radiation. 

The point that I am getting to: there are many materials that 
get into the lung and do damage; many materials that get into the 
gonadal tissue and can cause mutagenic effects. The question is, 
how thoroughly can we, as a group, society, study all of these pos- 

So I think there is a brighter side to this coin, too, that 
we indeed do know and have quite an amount of information for rad- 
ioactive material, but there is still a lot to be learned. How- 
ever, there has to be a very important national decision made, I 
think, in how much of our total resources can be committed. 


Let me give one other example. We are all fully aware of the 
situation that developed many years ago when the uranium miners 
worked deep underground. A fair number of them who smoked and were 
exposed to other materials developed lung cancer. However many 
> people seem to ignore the fact today that the tax bill for black 
lung disease of coal miners is $1 billion a year. That is $1 bil- 

My point is, and I think we all have to learn this -- there 
is a cost, a biological, environmental cost, for whatever we do 
We are only now learning how to quantitate this cost for different 
integrating cycles of producing energy. It is a two-sided ques- 
tion. I do agree there are areas that need additional work in the 
radiation field specifically. 

Dr. Morgan. Thank you. Dr. Caldicott? 

Dr. Caldicott. Of the most mutagenic agents, we know pluton- 
ium is one, and we have just heard evidence about how carcinogenic 
it is. In fact, it has been stated that there is no dose low enough 
which will not produce lung cancer in dogs. We know and we have 
heard that it migrates to the gonads, the testes and the ovaries. 

Six percent of all children born now have some sort of congen- 
ital defect; 30 percent of the admissions to all pediatric hospi- 
tals are related to inherited disease and deformity; 10 percent of 
all admissions to adult hospitals are related to inherited disease. 

As Plutonium is so mutagenic it most surely will produce mu- 
tations within the eggs and the sperm which will be obvious in 
future generations if it is deposited in the gonads, if it is in 
the atmosphere. 

If we go ahead with the plutonium economy, almost surely we 
will become contaminated; we are already from the fall-out. Do we 
risk our future generations of children? Is that the risk we are 
prepared to take for the benefit of turning on electric lights? 


Dr. Morgan. I would like at this time to call on representa- 
tives from ERDA. I see Bill Burr here; would you care to respond? 

Dr. Burr. Yes, sir. 

What I would like to do is discuss briefly the scope and gen- 
eral magnitude of the ERDA research programs in this area. 

I thought it might be useful to say a little more about some 
of the work that is currently under way. 

Dr. Mattson has touched on this. He has noted that we have 
perhaps $40 million or more in funds allocated for the health ef- 
fects area and it is this research about which I would like to 
speak. In addition, we fund research in the environmental area, 
including the movement of radionuclides through the environment. 

We also have work in our physical and technological programs 
for better instrumentation and procedures, but I really want to 


focus on the health effects studies. 

Of that $40 million, approximately $10 to $11 million are for 
human health studies. A number of these have been mentioned this 
morning, and I want to just touch on them again. 

In the epidemiologic area, our largest committment is in sup- 
port of the studies in Japan of atomic bomb survivors by the Radi- 
ation Effects Research Foundation, formerly the Atomic Bomb Casual 
ty Commission. The gentleman on my left, Mr. Jablon, can tell you 
more about this project. 

We have a major effort in the Transuranium Registry. This 
has been touched upon as well. We still have an extensive program 
at the Center for Human Radiobiology at the Argonne National Lab- 
oratory for the follow-up of radium workers and additional indi- 
viduals who were exposed, for other reasons, to radium. 

This work has been cited before and has been the benchmark 
as far as human data is concerned for bone seeking internal emit- 
ters. It continues to be an important area of research. 

We have a health and mortality study that does not embrace 
all of ERDA's activities but is quite large in its scope. It has 
been going on for a number of years. This study of workers ini- 
tially involved the workers at Hanford in Richland, Washington 
and those at Oak Ridge. It has been extended in recent years to 
some other laboratories. 

We are adding to our epidemiological efforts in plutonium. 
We agree that this is an area that needs to be strengthened. 

Rather quickly, the other portion of this $40 million, the 
$30 million or so, is devoted to our studies of experimental 
systems, and of this, about $10 million is in the internal emit- 
ter area. 

Since the question has been raised, I will point out of that 
approximately $8 million is devoted to the metabolism of alpha 
emitting radionuclides and their effects. Other studies involve 
radiation damage in organs and cellular and molecular systems. I 
will not go into that research. 

The genetic studies in experimental animal systems represent 
about $4 million of effort. 

In addition to this brief summary we have some descriptive 
material that I would like to leave with the committee. Dr. Morgan 

Dr. Morgan. Thank you very much. Maybe some of the panel 
members have questions they would like to direct to you? 

Mr. Myles of the Environmental Study Conference has a state- 
ment he would like to make at this time. 

Mr. Myles. I would like to add that we asked the National 
Cancer Institute what kind of research they are currently doing 
on radiation health effects, and we got responses from Dr. Marvin 


Schneidermann and Dr, Robert Miller who is the Chief of the Clini- 
cal Epidemiological Branch of the National Cancer Institute. 

Basically they said that the NCI is doing almost nothing, or 
, certainly nothing new in research in radiation health effects. 

Dr. Miller added that they have some continuing funds involved 
in support for the Radiation Effects Research Foundation, studies 
of head circumference among children who were exposed to that atom- 
ic bomb in utero, funds to the National Academy of Sciences, Nation- 
al Research Council for the study between the relation of pre-natal 
diagnostic x-ray exposure anc cancer in childhood and the Clinical 
Epidemiological Branch has issued a monthly Childhood Center Epide- 
miological Newsletter since 1973. 

This suggests, I think, to some people that the National Can- 
cer Institute should be doing more in radiation health effects re- 

Dr. Morgan. Dr. Bross? 

Dr, Bross. I think I should mention that I have been omitted 
from that list. That is because our research is on biometric re- 
search and cancer epidemiology and general methodology and not 
specifically on radiation hazards exclusively. I think that if we 
had gone in for funding on that, we would never have gotten the 
funding. I think that there is also other work being done by the 
NCI. Just for the record, I would read in our Grant Number CA11531, 
because these people like to have that mentioned. 

Dr. Morgan. Dr. Edsall? 

Dr. Edsall. The people that you consulted at the National 
Institute of Health, did they give a rationale for the decision 
not to have any but a very small program in this area? 

Mr. Myles. No, there was not any real attempt, as far as 
I could tell, to explain why they did not have more money or re- 
search funding involved. 

Dr. Edsall. Suppose they probably feel that because work is 
probably being done by other agencies in this area that they do 
not need to do it, but it does seem to me a very unbalanced kind 
of program in the NIH or the National Cancer Institute, that they 
have so much going on in the cancer field and almost nothing in 
this area. 

Dr. Morgan. Dr. Archer? 

Dr. Archer. I recall two studies that the National Cancer 
Institute have done pertinent to this discussion that were pub- 
lished fairly recently. One, the mortality study of the people 
in Mesa, Colorado, a county in which Grand Junction is located. 

They were especially looking for an increase in lung cancer 
which they failed to find. They did another study in which they 
attempted to do the sort of thing I was talking about earlier 
this morning, trying to relate cancer to background radiation. 


This was reported two years ago, I think. The results were 
negative. They found no effect. 

As they indicated this morning, I think they were working 
with some incorrect assumptions. 

Dr, Morgan. Mr. Jablon? 

Mr. Jablon. It is not really my place to spring to the de- 
fense of the National Cancer Institute but I should say that in 
conversations with the people there, two things have been plain. 
It is their feeling that other agencies, especially ERDA, have a 
primary interest in radiation effects per se and that there is no 
reason for them to go into competition. 

Secondly, that they do have an interest in cancer, and if 
anybody goes to them with a contract proposal or project which 
seems suited to their needs, investigating the epidemiology of 
cancer, they have been forthcoming. And in fact, as was mentioned, 
they have put fairly substantial funds into what was formerly the 
Atomic Bomb Casualty Commission, now the Radiation Effects Re- 
search Foundation at a time when, for various reasons, AEC was 
finding it difficult to find all the money that was required. 

So I think they have been responsive. 

Dr. Morgan. Thank you. 

The Chairman will declare a five-minute recess. 
(A brief recess was taken.) 

Dr. Morgan. Dr. Bertell has a comment she would like to make 
regarding the previous discussion. 

Dr. Bertell. I think that we were talking about the adequacy 
of the research and we have already talked about some of the as- 
pects, such as the understanding of the biological mechanism. 
Again, the way you understand the mechanism affects the way you 
look at the data and how you report it. 

We have talked about data collection and the inadequacies 
there. There is one other big area which has not been mentioned 
as yet, and that is the techniques of mathematical analysis of the 
data, and I think that that also is another big area which needs 
to be updated. I have worked quite a bit to try to update the 
handling of this type of data and the measurement of things which 
seem very vague, like the aging effect, which are hard to get a 
handle on. 

Unless we are willing, also, to update in the methodological 
area, I think that the research is inadequate. 

Dr. Morgan. Thank you. Dr. Bross? 

Dr. Bross, Presumably, since we are speaking about recommen- 
dations for congressional groups, that since one point did come 
out at the very end, namely funding of research, I would like to 
put a policy statement in at this point. 


You heard that the National Cancer Institute essentially was 
not funding very heavily in this area because it was relying on 
other agencies. This can happen when research responsibility is 
spread around. What I would like to recommend as a policy is that 
^health research be carried out by the agency whose mission is the 
'protection of the public health rather th&n by an agency with an- 
other mission. 


Chapter IX 

Health Effects to Occupational and General Populations 
Exposed to the Present Federal Standards 

Dr. Morgan. I think we had better go on now to the next 
question. We are going to have to select the remaining questions 
in order to conclude by 5:00 o'clock. 

Question 8, I think, has been addressed, perhaps sufficient- 
ly: What health effects would result from public and occupational 
exposure to the legal limits allowed by Federal standards? 

Dr. Mattson, would you like to address this? 

Dr. Mattson. If we understand the question correctly, it 
has already been addressed by the BEIR Committee. I think the 
numbers to answer the question come straight from the BEIR analy- 

Perhaps the conclusions were not precisely stated there, but 
it is a simple calculation, using the BEIR calculation model. 

I recall that the BEIR Committee used a base of 0.1 rem per 
year. I do not have the calculation performed for the assumption 
of the general population being exposed at the occupational limit. 
We have performed a calculation at 500 millirems, assuming that 
everybody in the United States was exposed to that level. It is 
a really large number. 

It ranges from something like 2.2 to 10.8 percent increase 
in cancer using that number, depending on whether you use the ab- 
solute risk model or the relative risk model of the BEIR Report. 

I think to say that the entire population of the United States 
would be exposed to 500 millirems from any given source is a bit 

We have made another calculation which might be more appro- 
pos to a specific source of radiation. That calculation used our 
regulatory design objectives for light water reactors effluents 
and assumed that everyone in the United States lives within a 62- 
mile radius of a two-unit light water reactor station, which is 
designed and operated according to our regulation. Within that 
62 miles we assumed a distribution of the population typical of 
what you might see for facilities operating today. 

Using the models for Appendix I to 10 CFR, Part 50, Design 
Objectives for the operation of these facilities, we could calcu- 
late over a 30-year operating life about five excess deaths -- 
if that is an acceptable term. In some circles, it is not; per- 
haps in this one, it is. Five deaths. That is compared to the 
normal incidence of cancer death in the United States in 1974 of 
350,000 people per year. 

I am sorry -- these are not deaths, it is the total number 
of cancers. In summary, the number we have calculated is 5 com- 
pared to 10,500,000 from other causes. 


I do not know if it was the intent of the question to get at 
these numbers. As you can see, it is kind of a numbers game. You 
can start out with the BEIR Committee numbers which are based on 
the linear hypothesis and use the upper limits standards. You can 
^ then go within those standards and say that not everyone in the 
'population receives the upper limit, so you have to assume some 
number for the population exposure. 

The number I have given has quite a lot of remaining conser- 
vatism in it, including the assumption that everybody lives within 
62 miles of a nuclear power plant, which is not the case. 

This is averaged throughout the U.S. population which is a 

mathematically accurate thing to do, using the linear hypothesis. 

But the end result is probably a meaningless number. It ranges 

from an insignficant fraction to a fairly significant fraction. 

Dr. Morgan. If I have done my arithmetic right, you are as- 
suming the average dose would be on the order of 10"^ of a rem 
(1/1, 000th of a rem, a millirem)? 

Dr. Mattson. We are assuming the whole body dose is the 
average for a population living within 62 miles of a reactor site. 
Let me test the number, if you would give me jsut a second. Fif- 
teen millirem per year is the maximum exposure. The average would 
be about one millirem. There is still some conservatism in that 

Dr. Morgan. I do not think so. 

Dr. Mattson. I am sorry; what is your question? 

Dr. Morgan. Just mental arithmetic here tells me you are as- 
suming about 1 millirem per year, using the BEIR data for all types 
of malignancies. 

Dr. Mattson*. No, sir, that is not the number that comes out. 

Dr. Morgan. Dr. Sternglass? 

Dr. Sternglass. In connection with the EPA hearings on March 
10th, I prepared an estimate as to what would happen if the pro- 
posed new standard of 25 millirem maximum which is now suggested 
as acceptable for the maximum limit for the nuclear fuel cycle 
were it to come into effect. 

This is what I did. I used the figures of the BEIR Report, 
3,000 to 15,000 cancer deaths annually for a dose of 5 rems over 
30 years, corresponding to 167 mrem per year. 

Under those conditions, the dose of 25 mrem that would be 
legally allowed per year will lear to approximately 15 percent 
of this number resulting in 449 to 2,245 cancer deaths per year 
in the U.S. Over a period of thirty years, this is from 13,470 
up to as high as 67,365 additional cancer deaths assigned to the 
gneration of nuclear electric power alone, not counting all other 
sources of manmade population exposure from fall-out, industrial 
uses, uranium mining or things that are not going to be covered 
by this 25 mrem standard. 



I must add to this, this is based on the linear hypothesis 
which is based largely on high dose-rate data. 

If indeed the membrane effect is important, and the latest 
animal studies show that the risk at low doses at low dose rates 
may be ten to a hundred times greater or more than, we are ending 
up with numbers that go into the hundreds of thousands. 

That is why I am so concerned about a major decision without 
looking into these numbers and into these low dose rate effects 
more careful ly . 

Dr. Morgan. Dr. Shleien, do you have a comment you would 
1 i ke to make? 

Dr. Shleien. Not really. It is just that we recognize, the 
Department of HEW was cosponsoring the BEIR Committee, and we re- 
cognize the results and use the results. We also recognize the 
fact that there are other groups that have evaluated the same 
problem, such as NCRP and that their opinion is quite different 
from the BEIR Committee conclusions, at least in estimation of the 
best available estimate and the estimation of the lower limits. 

Other than that, I do not have anything to add. 

Dr. Morgan. Dr. Ellett, what about EPA? 

Dr. Ellett. I particularly dislike this particular numbers 
game because I think you have to look at the probability for can- 
cer for a given dose of radiation, and the probability of someone 
receiving that dose. It is true that EPA limits, if you use a 
straight multiplication with the U.S. population yield the num- 
bers he indicated, but the limit is not the dose that people re- 
ceive. This (the limit) is the dose, to the highly exposed people. 
I can recall at least one EPA study,—' which indicated the average 
dose to everyone in the United States from the nuclear power in- 
dustry came out to something like half a millirem per year, a fac- 
tor of 40 less than proposed limits for the U.F.C. 

I am not saying that this results in a small number of health 
effects, rather that you have to remember that standards are set 
up for the most exposed person and do not mean that everyone in 
the population is in the most exposed group. Certainly the aver- 
age dose is going to be a lot lower than that to the most exposed. 

A possible exception is occupational exposure where indeed 
you may have people exposed up to the legal limit. This certain- 
ly is not true of the average radiation worker. EPA is looking 
at occupational radiation standards now, and it is very difficult 
from presently available data to find out what dose the average 
worker gets. 

For an occupational group to be exposed for a lifetime at 5 
rems per year, using BEIR risk estimates, it would appear that 
their average life shortening (due to cancer) would be something 
on the order of 3/lOths to 1/2 year, if an absolute risk model 
were used and about 1.6 times greater, if a relative risk model 
is used. Therefore, the average estimated life-shortening may 


be up to a year for occupational hazards if you were exposed at 
4 to 5 rem per year for a working lifetime. These are estimates 
similar to those given in the BEIR Report. 

I am not sure that the risk from 5 rem per year is even a 
fair basis of comparison. It looks like 1 rem per year would 
be very high for the average occupational exposure in the nuclear 
industry. Our own data tell us it is like 2/1 0th of a rad per 
year but we know a lot of zeroes are averaged into that data, so 
that I would guess average occupational exposure might be a fac- 
tor of 5 greater, i.e., 1 rem per year. 

As I indicated before, the life-shortening is something on 
the order of 1/2 year per radiation exposed worker at 5 rem per 
year. There is no epidemiological study that I know of that 
could measure this, regardless of the size of the work force ex- 

You might compare radiation risk at 5 rem per year to the 
risk of accidental death in industry. We have done this and it 
looks like that for that fraction of the radiation workers who 
receive 5 rem per year, they are up to two to four times the 
average risk for all American industry. 

Within any particular industry, there are people that have 
high risk jobs and low risk jobs. I do not know if it is com- 
pletely fair to take the highest risk for atomic workers and 
compare those to an average for a particular industry. It looks 
like the radiation workers have a risk somewhat comparable as to 
that of an agricultural worker. Agricultural work is not a par- 
ticularly safe occupation. 

Dr. Morgan. Dr, Bertell? 

Dr. Bertell. First of all, I do have the numbers here for 
the 1974 report on workers and one rad exposure was exceeded by 
5,342 workers in the power reactor and fuel processing and fab- 
rication industries. 

The average exposure of personnel in the U.S. nuclear plants 
was .965, which is essentially 1 rad. I think we are talking a- 
bout that exposure. 

I would also like to talk to the point of an aging effect, 
which, from what I gleaned you are saying, Dr. Ellett, is not the 
same as life shortening. That is tricky. 

Dr. Ellett. I have not discussed the aging effect. I ad- 
dress only premature loss of life due to cancer. 

Dr. Bertell. All right. 

Dr. Ellett. I am sorry if I did not make that clear. 

Dr. Morgan. Unless there is some burning desire to speak -- 
Dr. Bross? 

Dr. Bross, There was reference to the numbers game. While 
it may not have been the purpose of persons who created the BEIR 


Report, the fact is that the BEIR Report provides the favorite 
raw materials for this kind of numbers game. 

I would like to speak in terms of our test findings from 
the Tri-state. In the women who were receiving radiation prior 
to -- that is prior to and during pregnancy -- about a third of 
all the leukemia that occurred in their children was due to rad- 
iation. We can pin it down quite nicely. 

I know that there are very many people who do not like num- 
bers, large numbers anyway, and who do not like statistics. So 
I would like to just add one other point. I have here a copy of 
the correspondence dated October, 1974 dealing with exposure of 
a single worker at the nuclear fuel services. 

As you know, the permissible level is about 12 rem per year 
emergency peak exposure and long-term exposure to age N years of 
(M-18) times 5 rems. 

This particular exposure is not too great. The whole body 
exposure is less than 1 rem, 0.8 rem. What happened was that 
this particular young man only worked for a couple of months be- 
cause there was a spill apparently on his ankle. Consequently he 
went over his quota, and this short period is all he worked; but 
he shortly conceived a child, and then later conceived another 

The two children are both victims of Holder's Syndrome a 
very rare disease. This is a hereditary disease involving a re- 
cessive gene which is expressed as the deficiency of a particu- 
lar enzyme. As with every single case, and this is a single case, 
we can never be certain, absolutely certain, in this instance 
that radiation was in any way a factor or a contributing factor. 
We cannot do this with one case. 

That is why we have to go to larger scale studies. But I 
think that what you would get from this is while the general 
figures in these number games and so forth are very abstract, 
they can be very real to the person who happens to get this kind 
of exposure. As this young man put it, even at $3.75 an hour, it 
was not worth it. 

Dr. Morgan. Dr. Richmond? 

Dr. Richmond. I think several comments were made about the 
numbers games and it does give people on the scientific end prob- 
lems from time to time. 

What really is embedded in the way we get risk estimates is 
the principle of commutati vity , this is, you would get the same 
cancer yield, theoretically, if you had 100 rem delivered to 
10,000 people as you would if you had 10-3 or a millirem deli- 
vered to 1 billion people. 

Obviously, this is not the case. 

Dr. Sternglass. It could be an error in either direction. 
Dr. Richmond. That is just the point I am getting to. It 


may underestimate the situation for cases where the radiation 
doses may tend to be higher than the average. 

I think that this is the problem with this particular ap- 
, proach because the classic example is that you cannot necessarily 
change the sequence of things. The principle of commutati vity . 
The best example is that it is not the same to put your shoes 
on over your socks as it is to put your socks over your shoes. 

An example of the numbers game I do not mean this to be 
serious, but it gives you an idea of the hazards you can get in- 
to. If we know the U.S. intake of aspirin today, any day, is 
approxiamtely 40 tons, this is nationwide, for a 1 gram intake, 
on the average, a person will lose about 1 milliliter of excess 
blood from gastrointestinal bleeding. You take the aspirin be- 
cause there is a risk-benefit; it does good for us. 

Using the same principles that we use in the man-rem linear 
hypothesis, by simple arithemetic, and assuming four liters of 
blood would be lethal in one man, then this 40 ton per day would 
cause 10,000 deaths per day. 

And I think that there is some wise guidance in the document 
I mentioned earlier, NCRP Publication 43 about the hazards invol- 
ved in the misuse of the man-rem concept. 

!_/ Office of Radiation Programs, Environmental Protection Agency. 
Estimates of Ionizing Radiation Doses in the United States, 
1960-2000. Washington, D.C. August 1972. Govt. Print Off. 
ORP-CSD-72-1 . 


Chapter X 

The Cost-Benefit Theory of Federal Radiation Standards, 
, Is It a Proper System? What are Alternative Systems? 

Dr. Morgan. I will have to draw this discussion to a conclu- 
sion and go to question 11. 

This question is. Explain the cost-benefit theory on which 
the Federal radiation standards are based. Is this a proper sys- 
tem to use? Is there a better one? 

I will call on Dr. Mattson to make any comments that he 
wishes on cost-benefit analysis. 

Dr. Mattson. I suppose we ought to start out by understand- 
ing what we mean by radiation standards. If we mean the recommen- 
dations of the NCRP, ICRP, Federal Radiation Council, as those re- 
commendations are expressed in NRC regulations, 500 millirem, 5 
rem, 170 millirem, those numbers, then Federal radiation standards 
are not based on a cost-benefit analysis, not as we would define a 
cost-benefit analysis today. 

They were based on comparative risk to some extent. We have 
heard Dr. Morgan and some others talk about trade-offs that were 
made, e.g. comparing safety of workers at 5 rem versus other kinds 
of hazard to other workers. 

Bill Ellett talked about some work EPA has done as a risk 
analysis rather than a risk-benefit analysis. 

I do not know the genesis of this question. Let me just talk 
for 30 seconds or so. Maybe I can get us to the point where we 
want to be. 

In implementing as low as reasonably achievable or as low as 
practicable, the admonition of the standards recommending bodies, 
the Atomic Energy Commission in about 1971-72 initiated a rule- 
making hearing to define design objective values for releases of 
radioactive materials in eflluents from light water reactors. 

That was about the time of the National Environmental Policy 
Act. They did a cost-benefit analysis pursuant to an Environmental 
Impact Statement in issuing these regulations. 

What those really were, were cost-effectiveness studies. They 
look at additions to control equipment to reduce calculated doses 
to individuals and populations. That information is a basis for 
decision-making by a duly appointed authority. That decision was 
made, and we speak of that today as a justified radiation standard. 

Perhaps Bill Ellett would like to talk about the cost analy- 
sis, the benefit analysis that was done for the now proposed uran- 
ium fuel cycle standards for EPA. 

Before I let him do that -- I will note that I am going to do 
that -- we think that there is something broader that ought to be 
considered in the setting of standards. We have touched on that, 
many of us here today, I think. 


Mr. Chairman, you talked about that briefly. That is a com- 
parison of cross-technologies of costs and benefits. 

Risks, we have talked about today. In costs, I include the 
, word "risks." We are talking about cost-risk-benefit analysis, 
dollars and cents in the sense of paying for control technology or 
control equipment, risk in the sense of doses to individuals and 
doses to population and benefits in the terms of electricity gen- 
erated for the consumer or whatever other benefits. 

We took a position in the EPA hearing on the fuel cycle stan- 
dards, which may be the source of this question which may be mis- 
understood by some people, but I think it is fairly clear how we 
stated it, and that was, we have existing today radiation stan- 
dards for individuals which have not unanimous but certainly wide- 
spread support from the scientific community. That is, 500 milli- 
rem per year and 170 millirem per year per population group as I 
discussed today. 

If those limits include the admonition to stay as low as rea- 
sonably achievable below those numbers, that is basically the sys- 
tem of regulation that we have. 

We feel that that is a good system, that it works, and we are 
keeping doses significantly below those numbers, and we agree with 
the BEIR Committee in a sense that we can keep doses on the aver- 
age to people in the United States below a millirem per year in 
the year 2000 and we are doing it. .03, .04 millirems per year on 
the average, I believe, is that number that was used this morning. 

If we are going to change that system of regulation, we ought 
to have a reason for changing it. We ought to know that we can 
achieve greater health benefits, if you will, or that is decrease 
the risk. 

We took a position in the EPA hearing that when the fuel cy- 
cle standard was being proposed that would replace the 170 and 500 
millirem by a number of 25 millirem to the whole body, it would 
establish a system that achieves essentially what is being achieved 
today but would require a significant spending of money in order 
to achieve the new system. 

We said on the basis of cost and benefits, that we did not see 

any increased benefit to man. We do not think the number of health 

effects could be measured, and we did see substantial cost in what 
EPA was proposing. 

We did not recommend promulgation of the standard, but we did 
not say raise the standard that exists today, and we did not say 
raise the doses that exist today. We said that what was proposed 
accomplishes essentially the same thing as the already existing re- 
gulations. If the standards are to be lowered, they ought to be 
lowered on the basis of a showing of need to avoid unacceptable 
health effects. 

I guess that is about all I have to say on cost-benefit. 

Dr. Morgan. I have been rather pleased that members of your 


staff have used a larger figure for the cost of a rem. I have 
heard them use on several occasions $1,000 per rem. 

We know sometimes a figure is used as low as $10 per rem. I 
believe that this conservatism of NRC is to be admired. I hope it 
is possible to maintain this. 

Perhaps Roger, or some of the others, would like to go into 
this in more detail, but for calculation purposes, for planning 
purposes, we have to decide whether it is worth the investment to 
clean up this radioactive gas, to reduce the occupational exposure, 
to reduce the amount of radio-iodine emitted into the environment. 

Do you figure the cost of bringing about these remedial changes 
in the procedure? What is the meaning of this? If it costs more 
than $1,000 to bring about these changes, more than $1,000 to re- 
duce 1 man rem, would one pause to decide whether it is worth the 
investment? If it costs less than $1,000 per rem, then can one 
consider seriously making this investment to reduce exposure and 
decrease the man rem? 

By man rem, we mean exposure that is arrived at by taking the 
number of persons in the population and multiplying it by the aver- 
age dose received by that population. For the mathemetician , it 
is the summation of the number of people in each exposure group 
times the dose received by each group of the population. 

Dr. Mattson. Yes, sir. It is important to recognize, first 
of all, under our system of regulation, there are some specific 
standards for the protection of individual members of the general 
public living off-site of nuclear power reactors. Those numbers 
are dependent upon the pathway, i.e., the way that the radiation 
reaches human beings. 

In the case of the liquid pathway, the number is 3 millirem 
per year; in the case of a gaseous pathway, it is 5 millirem per 

After an applicant for a license to operate a nuclear power 
plant has shown that he can protect individuals around his site to 
that degree, then we look in addition at the protection that he 
provides to the population within a 50-mile radius of the site. 

To do that, we look at the doses to people distributed within 
that area. Those doses are summed mathemetical ly . Then in the 
analysis we add equipment, according to the state of the art, for 
effluent control . 

If the equipment in incremental additions costs more than 
$1,000 per man-rem reduction in the population exposure, then 
equipment need not be added to the facility. If it costs less 
than $1,000 per man-rem, the equipment must be added. 

As you alluded, the value of $1,000 per man-rem reduction of 
population exposure generally is considered to be conservative, 
and the literature has spoken to that. 

Dr. Morgan. Dr. Edsall? 


Dr. Edsall. I would like to raise the question in this con- 
nection of what is to be considered an acceptable risk, and it 
seems to depend a great deal on the kind of thing that one is con- 
cerned with. 

The present standards for plutonium exposure must be consi- 
dered in the light of the general concept of acceptable risk. K'.il. 
Bair, one of the top experts in the study of plutonium effects in 
animals, has estimated that about one person in eight, carrying 
the "permissable" lung burden of 16 nanocuries of plutonium, might 
develop a lung tumor in the course of the years, if humans are as 
susceptible to plutonium as rats. If plutonium were (for instance) 
a food additive, this would be considered completely unacceptable. 
An advisory panel of the FDA, on food additives and pesticides, 
wrote in its report: "No one would wish to introduce an agent into 
a human population for which no more could be said than that it 
would probably produce no more than two tumors per thousand."!/ In- 
deed the panel indicated that testing ought to indicate less than 
one tumor produced per million animals, if it were to be considered 
satisfactory and safe. Plutonium, of course, is not a food addi- 
tive or a pesticide, but a fuel and the chief ingredient of the 
most deadly known weapons; but the difference in criteria for ac- 
ceptability in the two cases seems to me to be glaring, and we 
ought to think more deeply regarding what we should consider as 
acceptable when we deal with radioactive poisons. 

Dr. Morgan. Question from the audience? 

Ms. Hornblower. Martha Hornblower from the Washington Post. 

I wonder whether one of the officials from FDA could respond 
to Dr. Edsall 's remarks on the comparability of toxic substances 
standards and radiation? 

Dr. Morgan. Would someone from the Bureau please comment? 

Mr. Barnett. I do not think our expertise in the Bureau is 
such that we are able to comment on that. 

Dr. Morgan. I would like now to call on Dr. Ellett to give 
the view of EPA. 

Dr. Ellett. I think that Roger Mattson has given at least 
one definition of the possibility of cost-benefit of balancing. 
Now I would like to look at some other ways. 

I suspect the best system to use depends on a particular case. 
Federal Radiation guidance was based on balancing some kind of a 
benefit against its costs, but included also a risk benefit bal- 
ancing where it was assumed there would be a risk from radiation 
and that this risk should be small compared to the benefits that 
are gained from using radiation. 

On the other hand, our drinking water legislation called for 
levels for radioactive substances that were as low as feasible, 
taking water treatment costs into consideration. 

Certainly when we look at how ICRP considered occupational 


79-767 O - 76 - 9 

recommendations, they looked at risks in other industries to try 
to achieve some kind of balance of risk against risk. 

The cost-benefit theory or balancing has been recommended 
really as a means of determining what is as low as readily achiev- 
able. However, it may presume you have much better data than you 
usually have. I think in radiation work, we are particularly for- 
tunate in that we feel that we have some idea of what the benefits 
are in reducing health risks as we reduce dose. Even though this 
is based on arguable assumptions, you have some data on cancer and 
genetic effects, and you have some idea of what, for a particular 
piece of dose reducing equipment, the cost is. For other energy 
sources this is not true. 

I do not think that standards from the uranium fuel cycle, for 
example, that EPA has proposed, that Roger Mattson refers to, can 
be broadened to consider the production of energy from all alter- 
nate sources of energy, for example by balancing risk and cost for 
radiation exposure due to the uranium fuel cycle, as opposed to 
balancing risk and health effects due to coal, oil or solar power. 
We simply do not have information on what the health effects are 
for all energy sources nor in large measure, do we have information 
on what equipment control costs are. 

Congress has addressed this question for some pollutants. In 
the Air Quality Standards for example, they say air quality should 
be at some margin of safety which will not show health effects. (It 
is easier perhaps for a Congressman than a scientist to say what 
effects occur, at what level.) But I think this illustrates there 
are different ways of approaching the setting of standards. 

It is very difficult to do such balancing for exposure to the 
general population. We assume that health risks at 500 millirem 
to an individual are so small that we should accept these; but then 
look for ways to achieve a smaller dose based on some kind of ra- 
tional basis on how you spend money to reduce the risk further. 

I do not know what kind of balancing was done for the histor- 
ical 500 millirem annual limit to individuals. I am not convinced 
that scientists are any better able to evaluate what the risks from 
500 millirem per year is worth in dollars than nonscientists. These 
are essentially political decisions in an economic context, and 
this is the sort of thing that should be subject to more consider- 
ation by legislative bodies and the public in general. 

We have to decide as a people as a whole, not radiation scien- 

I have a little problem with a cost-benefit balancing that is 
arbitrary such as $1,000 per man-rem. I feel a man-rem is equiva- 
lent to so much in human life, this puts us in the very difficult 
situation of assessing human life in dollars. Some have argued 
that we do this every day, but I am not convinced that these argu- 
ments are all that persuasive. 

Dr. Morgan. I will take two more comments -- 

Dr. Charles. May I ask a question? 


Dr. Morgan. Our program is to take one more written question 
and ask for remaining questions from the floor. 

Dr. Charles. This has to do with cost-benefit. 

Dr. Morgan. That is fine. You can ask that. 

Dr. Charles. I have something else to ask. May I say some- 
thing about cost-benefit? I am a pediatrician and as I listen to 
discussion about cost-benefits which is the politicians' way of say- 
ing they don't want to spend money for health, I tell you for 
years, I have been trying to get safe school iDuses on the American 
highway. This is what I hear all the time; -- no funds available 
until the public pressure builds. 

We do not talk about cost-benefits when we have a tiny pre- 
mature that needs thousands and thousands of dollars put into it 
to save a life. I do not understand how you can equate the lives 
that you are talking about today here with cost-benefits. It seems 
to me to be unfair to the American people to use this kind of ana- 
lysis. We did not use cost-benefit analysis in Vietnam. 


Dr. Ellett. May I respond to that in part? 
Dr. Morgan. Yes. 

Dr. Ellett. I think it would be very easy if we could say 
thousands of dollars would save a human life. Roger Mattson was 
talking about something like $4 million to save a statistical hu- 
man life and at that level of expenditure, society has to decide 
if this is the place to spend $4 million. 

These are hard decisions to reach when you are talking about 
that kind of money. I think it is up to our government in the 
form of our legislature and the Executive Branch and the people 
as a whole to decide where is the best place to spend this money 
to make life better for all of us. It is a lot of money. 

Dr. Morgan. Now, we have opened up the floor -- I had in- 
tended to put that last -- we will continue. 

You had a question, Dr. Collins? 

Dr. Collins. With respect to cost-benefits, in 1974 for 
84,097 workers monitored, 88.4 percent were already below 0.5 of 
a rem in that year, so what we are really looking at here is the 
cost of reducing radiation for the 11.6 of workers who got above 
that. In going through the data for a number of plants we 
found that a considerable number of plants already comply with a 
limit of 0.5 rem per year for their workers. 

The improvement is needed in the bad plants, the plants such 
as Kerr-McGee at Cimarron which had shocking conditions. There 
are a number of other plants in the 1974 report where the situation 
is bad from the standpoint of radiation exposure to workers. 



In other words, there is no question that technologically re- 
duction of the maximum exposure level to 0.5 rem per year is prac- 
tical. It is realizable. It is not that we are calling for a re- 
duction by 10^ or 10^. We are talking about something which, from 
the engineering standpoint is quite feasible. It may cost some 
people some money. 

We would concede that it may affect the sloppy engineering 
that goes on that allows a situation as in West Valley, where tran- 
sient workers are called in and given a few hours exposure and then 
yanked off the job. Then as we know, years later, these transients 
can suffer the consequences of their exposures. 

Dr. Morgan. I will take one more question from the floor. 

The gentleman in the orange shirt. 

Mr. Kepford. I would like to state a couple of comments with 
regard to cost-benefit. I think the important thing we should 
consider when talking about cost-benefits, if we must use this, 
is cost to whom and benefit to whom. We have not touched on that 

When we talk about the costs of installing this radiation 
holdup equipment, we talk about the cost to the utility, but in 
reality the utility does not pay one red cent of these. It is 
added to the rate base. They earn a return on it. 

Not only do they get their money back, but they earn money 
on it. The cost to the utility is zero. The cost is passed on 
to the rate payers. The rate payers pay the cost. 

Who gets the benefit? In reality, the cost of your electri- 
city is a part of the cost. You pay for that. That is not a bene- 
fit. The benefits accrue to the stockholders They get more than 
what they paid for when they bought the stock. They get the bene- 

The real costs we are talking about are the health-costs. 
Those are the ones that are important. 

Now, with regard to the NRC's rules and regulations, of which 
we have heard much today, at a bare minimum they are only as good 
as the NRC's willingness to enforce them, and frequently in the 
past, the NRC has been totally unwilling to enforce them, and I 
use this one simple example: the as low as practicable guidelines. 

It is only because of a court decision dated December 9, 1975 
that the NRC was required by the District of Columbia Court to en- 
force the as low as practicable guidelines. I will offer the 
Board a copy of that decision. 

Dr. Morgan. I would appreciate it. You can submit it for the 

Dr. Mattson. One minute. We have to get to the last question. 
First of all, on the cost-benefit criticism, we agree that those 
are important considerations. In that regard, the Nuclear Regula- 
tory Commission has announced its intent to hold a rule-making on 


whether there are alternative ways to make these decisions. If 
there are not, what is the proper value for making these cost-bene- 
fit trade-offs in population exposure and reductions. That is com- 
ing up in the future sometime. 

I would be interested to hear your views on that. 

With regard to the court decision, there is a slight nuance 
to that Court decision. When Appendix I, the Design Objective for 
Light Water Reactors was issued last May, there was a grace period 
for reanalysis and for buying equipment for operating facilities 
and for change of facilities in the design or construction process. 
That grace period is up this summer. June 4th is a date that 
sticks in my mind. 

The AEC staff and the NRC staff, which was responsible for li- 
censing actions while the rule-making was going on, made an in- 
terim decision. What they did was adopt a very conservative posi- 
tion, as it turned out, more conservative than the subsequent de- 
cision on Appendix I. 

When the decision came out, there was a question for some 
plants about to go on line as to whether they needed to go through 
some very sophisticated analyses required by this new regulation, 
or whether they could stay in operation using the old conservative 
basis, i.e., whether that was a bad rationale. They were providing 
better protection, was that not good enough? 

The court decision that you have referenced ties into that 
very complicated legal and procedural argument about the timing 
of the application of the regulation, that is all. We were en- 
forcing Appendix I -- in fact, we were enforcing something more 
stringent than Appendix I. We are today and will be doing so un- 
til June 4th of this year when Appendix I goes into full effect. 

!_/ U.S. Food and Drug Administration. Advisory Committee on 
Protocols for Safety Evaluation. Panel on Carcinogenesis 
Report on cancer testing in the safety evaluation of food 
additives and pesticides. Toxicology and applied pharma- 
cology, V. 20, Nov. 1971: 419-438. 


Chapter XI 

Specific Recommendations for Congressional Hearings. 
Legislation or Other Actions 

Dr. Morgan. We must come now to the last question, and we 
must conclude not later than 5:00 o'clock. 

The last question; the staff tells me, we must ask the panel, 
What recommendations do you have for specific congressional hear- 
ings, legislation or other action to better protect the public and 
workers from low-level radiation? 

Dr. Bross. I would say in summary you have more than enough 
solid, scientific evidence of the hazards of accumulated genetic 
aggregation to justify immediate public health measures to protect 
the American public against exposures to the low-level radiation, 
particularly unnecessary low-level radiation. 

In the medical area, it is now possible to reduce the expo- 
sure by a factor of 10, involving such things as mandating the use 
of high quality films instead of cheap industrial films which are 
often used, and a lot of other technology. We have the technology 
to do the job of cutting the exposure to the public from medical 
x-rays by a factor of 10. There is not a lot of argument about 
this point. 

We are not doing it. The job for Congress is to see that this 
gets done. 

In the nuclear power area, you have already heard several 
times that the present level of radiation of 5 rems a year should 
be immediately reduced and can be immediately reduced by a factor 
of 10. 

One thing I learned, just by casual talking around the table, 
that this reduction may unofficially be acceptable to several 
members of the regulatory agencies. They have their own personal 
views as opposed to the offical views of their agencies. There is 
something in process, but it is dragging. 

My third recommendation is different in character, and that 
may seem like a very drastic change. In brief, what I would like 
to suggest for consideration is that we should make murder by tech- 
nology a criminal offense. Therefore, we should put people who do 
stupid things with technology that kill other people in prison for 
a couple of years. I do not think anything would do better to give 
people second thoughts about whether to put these chemicals into 
the environment, to put unncessary radiation into the environment 
than the thought that they may go to prison for a couple of years 
as chemists, as businessmen, as members of regulatory agencies, 
and I think that this would have a salutory effect. 

Dr. Morgan. Thank you. Next we will hear from Dr. Bertell. 

Dr. Bertell. I agree with Dr. Bross. I also have a sheet of 
written recommendations. Is it permissible to submit this? (See 
Appendix.) I have copies for anyone else who would want one. 


Pretty much they have been stated, but I think it summarizes my re- 

What I would like to speak for is a change in attitude. I 
think I speak for many millions of Americans, and I would like to 
ask that we take a look at man and say, what can he do, what is so 
wonderful about him that is as yet an untapped source, instead of 
saying, how much abuse can he stand. 

I would ask that when we try to assess a problem, we place 
quality of life higher than GNP. 

I would ask that we place a higher priority on health than on 
energy. Man would be better off with less hurry, with a more con- 
templative lifestyle. It is not necessary to have all of this en- 
ergy. It does not improve our standard of living. 

Dr. Morgan. Dr. Sternglass? 

Dr. Sternglass. I would like now to point out and to recom- 
mend and urge strongly that Congress mandate population studies of 
the type that were recommended in 1963 by the Joint Committee, but 
have never been carried out, that these should be carried out un- 
der the auspices of the EPA by independent groups and universities 
using the best statistical methods available, that this kind 
of funding if necessary should be taken from the studies of other 
types which are not so directly related to the very urgent ques- 
tion of human exposure and human effects studies. 

I believe that furthermore Congress should hold hearings on 
the kinds of studies to be carried out on animals and large human 
populations, the very low doses and dose rates, because the indi- 
cations are that these are not being adequately done now. I think 
Congress has a right to know before appropriating money for any 
further research and development in this area whether or not our 
present experience with human exposure has been adequately evalu- 
ated or not. 

I believe further that these studies should extend to pat- 
terns of worldwide fall-out. They should extend to patterns of 
health effects around various nuclear facilities and that this 
should be a high priority mandated by Congress. 

I think also that it would be important to investigate in Con- 
gress some time why some of these effects were not investigated 
earlier, why so few scientists find it possible to work in this 
area without fear of losing their jobs or their grants. This en- 
tire question of secrecy in this whole area has dimensions which 
I think may approach those that we have only recently recognized 
with regard to our intelligence agencies, the CIA and the FBI. 

I am deeply concerned that many scientists who had informa- 
tion that could have helped to save human lives were prevented 
from publishing, prevented from bringing it out in the open, and 
that this kind of investigation must be carried out because we are 
going to be dealing with an agent in the environment which cannot 
be seen, cannot be felt, and cannot be smelled. Unless we find a 
way to solve the social problems of dealing with this source of 


energy, then I believe that it cannot be used without risking our 
society's future. 

Dr. Morgan. Thank you. 

Dr. Martell? 

Dr. Martell. We have heard today that the BEIR Report is out 
of date and also has not given consideration to certain important 
questions. I recommend that among other things, we should consider 
reconvening the BEIR Committee, or parts of it, to consider impor- 
tant questions that have not yet been addressed. 

We have, first of all, a current review of the "hot particle" 
risk on which, I understand, the BEIR Committee members have mixed 
reactions. They certainly are not in agreement. They must also 
consider the issues raised by my "warm particle" hypothesis and by 
the multiple mutation process. 

If a multiple mutation process is involved, as I mentioned 
before, alpha emitters become not just a contritDuting factor but 
perhaps a principal agent of cell mutation and cancer. I think 
that the BEIR Committee should review the evidence for and the 
implications of a multiple mutation hypothesis and process. Other- 
wise we will be basing important decisions for the future, 
for future generations, -- on a linear hypothesis which has so 
many shortcomings that it is befuddling. 

Finally, I suggest that it is overdue that the BEIR Commit- 
tee and others consider the microdistribution of internal emitters 
in the gonads with emphasis on, but not restricted to, alpha emit- 
ters. And they should specifically look in the sperm and ova, be- 
cause we already have an indication that there may be more polon- 
ium and Plutonium at these critical sites. Let us find out. The 
second area that has been bothering me became more evident today. 
It seems that the emphasis on cancer research in this country has 
been restricted to chemicals and virus as agents, with no adequate 
attention to radiation for which there is no question of human mu- 
tagenic and carcinogenic effects. It seems to me that this area 
deserves far more than a few percent or less of the cancer research 
effort of this country. 

In this connection, I suggest that it is long overdue that 
the National Cancer Institute establish a substantial program of 
radiation-induced cancer research. Within such a program there 
should be a high-priority given to the study of the micro-distri- 
bution of the internal alpha emitters at the tumor sites in high 
risk groups. (See Appendix.) 

Thank you. 

Dr. Morgan. Dr. Ellett, did you have a comment? 
Dr. Ellett. No. 

Dr. Morgan. We have one or two more minutes yet before we 
concl ude. 


Dr. Caldicott. My recommendations are (1) that medical ex- 
posure should be reduced, that there should be a requirement that 
the dose of radiation of the x-ray should be written on the x-ray 
so summation of radiation dose to each person can be tabulated. 

(2) There should be an official Congressional hearing on the 
medical dangers of proceeding with nuclear power. (3) There 
should be an offical policy to educate the public on the genetic 
mechanisms and consequences o'*' radiation -- the risk benefit fac- 
tor -- presently the governments of the world are spending mil- 
lions of dollars to find a cure to cancer, leukemia and congeni- 
tal diseas. Yet the same governments are spending billions of dol- 
lars on the nuclear industry and nuclear weapons which will direct- 
ly lead to proliferation of these diseases. 

(4) I would recommend that we stop all nuclear power devel- 
opment until and whenever we can prove it is safe. (5) I would 
also recommend that we stop this country and others from exporting 
nuclear power plants, which will lead directly to proliferation of 
nuclear weapons which threatens the future of life on earth. 

Dr. Morgan. I would recognize the gentleman. 

Dr. Charles. I want to conclude by saying as a citizen of 
New Jersey and New Jersey having the distinguished position of 
unquestionably having the highest cancer rate in the country today, 
I can tell you that we are very frightened. 

As a representative of the medical profession and citizenry 
there, we are disturbed with the plan to put new nuclear reactors 
in Atlantic City, a plant that has been designated as a first-gen- 
eration technology. We do not know of any reassurances from the 
regulatory agencies which will allow our people to live in any 
kind of peace and safety. 

I ask, therefore, seconding what Dr. Caldicott has said, that 
there be a moratorium on further nuclear reactors, in New Jersey 
especially, because we have had enough cancer, until you can come 
up with the answers that obviously are not evident here today and 
enough agreement about the need for further research. We do not 
want to be statistics. 

Thank you. 

Dr. Morgan. I would like to thank the panelists and the 
audience for their perseverance and their participation in this 
discussion here. I declare the meeting adjourned. 

(Whereupon, at 5:00 p.m. the conference adjourned.) 



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Aging Effect: The theory that radiation produces an acceleration in 
the aging process. 

Alpha Particle: A charged particle which has a mass and charge equal 
in magnitude to a helium-4 nucleus and is emitted from the 
nucleus of an atom. 

Alpha Rays: Alpha particles emitted by radioactive elements. 

Background Radiation: Ionizing radiation present in the area of 
interest and coming from sources other than that of primary 
concern . 

BEIR Report: A report prepared by the Advisory Committee on the 

Biological Effects of Ionizing Radiation, Division of Medical 
Sciences, National Research Council of the National Academy 
of Sciences. The report is entitled "The Effects on Populations 
of Exposure to Low Levels of Ionizing Radiation." 

Bioassay: The determination of the effect and/or strength of a sub- 
stance by administering it to one test organism and a standard 
preparation to another test organism and then comparing the rela- 
tive effects. 

Body Burden: The total quantity of a radionuclide present in the body. 

Bone Seeker: Any substance which migrates, in vivo, preferentially 
into bone. 

BRH: Bureau of Radiological Health of the Food and Drug Administra- 
tion, U.S. Department of Health, Education, and Welfare. 

Cell Sterility: The inability of a cell to reproduce. 

Chronic Exposure: Radiation exposure of long duration by fractiona- 
tion or protraction. 

Congenital: Existing at or dating from the time of birth. 

Cosmic Rays: Strongly penetrating rays which come from beyond the 
Earth's atmosphere and contain particles which move at ex- 
tremely high speed. 

Curie: The special unit of activity. One curie equals 3.7 x 10-^*-* 
disintegrations per second. 

Cytology: A branch of biology which deals with the structure, function, 
multiplication, pathology, and life history of cells. 

These definitions are adapted from a variety of sources. 


Deleterious: Hurtful, noxious. 

DNA: The abbreviation for deoxyr ibonuc leac acid which is a nucleic 
acid found especially in the cell nucleus and is thought to be 
the genetic material. 

Dose Rate: Absorbed dose delivered per unit time. 

EPA: Environmental Protection Agency. 

Epidemiology: A science that deals with the study of epidemics by 
observing the incidence, distribution, and control of disease 
in a population. 

Extrapolate: To project, extend, or expand known data or experience 
into an area not known or experienced in order to arrive at a 
new, conjectural knowledge of the unknown area by inferences 
based on an assumed continuity, correspondence, or other paral- 
lelism between it and what is known. 

Gamma: A unit of magnetic field intensity equal to ten oersteds. 

Gamma Radiation: Electromagnetic radiation emitted in the process of 
nuclear transition or particle annihilation. 

Gamma Ray: Short wavelength electromagnetic radiation of nuclear ori- 
gin (range of energy from 10 KeV to 9 MeV) emitted from the 
nuc leus . 

Genetic: Relating to the germ cells which contain the genes that deter- 
mine the characteristics of the offspring. 

Geomagnetic: Of or relating to terrestial magnetism. 

Health Physics: The application of the science of physics (and here - 
radiation physics) to health problems. 

Homeostasis: A relatively stable state of equilibrium or a tendency 
toward such a state between the different but interdependent 
elements of a group. 

Hot Particle Controversy: The disagreement about the relative car- 
cinogenicity of various sizes of particles of plutonium when 
inhaled into the lung. 

ICRP : International Commission on Radiological Protection. 

Internal Emitters: Radioactive substances which emit radioactivity 
when taken inside the body. 

Interpolate: To estimate the values of a function between two known 
values . 


In Utero: Before the time ot birth; while in the mother's 
womb . 

Iodine : A radioactive form of iodine. 

Ionizing Radiation: Any electromagnetic or particulate radia- 
tion capable of producing ions, directly or indirectly, 
in its passage through matter. 

Kilorad : 1 ,000 rads . 

Linear Energy Transfer (LET): The average energy locally imparted 
to a medium by a charged particle of specified energy per 
unit distance traversed. 

Linear Hypothesis: The assumption that a dose-effect curve derived 
from data in the high dose and high dose-rate ranges may be 
extrapolated through the low dose and low dose range to zero, 
implying that, theoretically, any amounts of radiation will 
cause some damage. 

Lymphatic System: A tubular system supplementing the blood vascular 

system of vertebrates; it collects lymph from the tissue spaces 
and returns it to the venous circulation; it is located in the 
spleen, lymph nodes, thymus, and tonsils. 

Mammography: A radiologic technique now widely used to aid in the 
diagnosis of breast cancer. 

MESA: Mine Enforcement Safety Administration. 

Microcurie: One millionth of a curie (3.7 x 10'^ disintegrations per 
second) . 

Millirad: One thousandth of a rad. 
Millirem: One thousandth of a rem. 
MIT: Massachusetts Institute of Technology. 

NCRP: National Council on Radiation Protection and Measurements. 

NIOSH: National Institute of Occupational Safety and Health. 

Nonionizing Radiation: Any electromagnetic or particulate radiation 
which does not contain enough energy per unit to produce ions 
in its passage through matter. 

NOX: Any one of a group of oxides of nitrogen. 

NRC : Nuclear Regulatory Commission. 

Organ Burden: The total quantity of a radionuclide present in an organ. 


OSHA: Occupational Safety and Health Administration. 

Overkill: To obliterate a target with more force than required. 

Particulate: Minute separate particles. 

Picocurie: One millionth of a microcurie (3.7 x 10~^ disintegrations 
per second ) . 

Rad : The special unit of adsorbed dose. One rad equals 100 ergs/gram. 

Radioisotopes: Radionuclides having the same atomic number but dif- 
ferent mass numbers. 

Radionuclide: A radioactive species of atom characterized by its mass 
number, atomic number, and energy state of the nucleus, provided 
that the mean life in that state is long enough to be observable. 

Radium: An intensely radioactive shining white metallic element that 
resembles barium chemically, occurs in combination in minute 
quantities in minerals, emits alpha particles and gamma rays to 
form radon, and is used chiefly in luminous materials and in the 
treatment of cancer. 

Rem: The special unit of dose equivalent. The dose equivalent in rems 
is numerically equal to the absorbed dose in rads multiplied by 
the quality factor, and any other necessary modifying factors. 

Sarcoma: A malignant neoplasma (tumor) arising in tissue of mesodermal 
origin (connective tissue, bone, cartilage, or striated muscle). 

Somatic: Not destined to become a germ cell; not genetic. 

SOX: Any one of a group of oxides of sulfur. 

Synergistic: Having the capacity to act in a cooperative action of 

discrete agencies such that the total effect is greater than the 
sum of the effects taken seperately. 

Transuranium Elements: Elements which have a higher atomic number 
than uranium; they are all radioactive; example, plutonium. 

Ultrasound: Vibrations with the same physical nature as sound but with 
frequencies above the range of human hearing. 

WASH 740 Report: A 1957 Atomic Energy Commission report which concluded 
that a major release of radioactivity from a small reactor could 
kill or injure thousands of persons. 

Zero Release: The prohibition of the release of any radioactive materials 
from a particular nuclear plant. 


Addition to the Testimo ny of Dr. Vi ctor E. Archer. M.D. from a 
Letter to Mr. Bruce Myles. April 1, 1976 . 

Even though natural ionizing radiation has probably 
played a useful role in the evolutionary history of man, it must 
now be regarded as potentially harmful to man. The reason for this 
is that man has so insulated himself from the forces of nature 
that a philosophy of "survival of the fittest" is much less appli- 
cable to man than to other species. Consequently, even small 
amounts of radiation, through induction of malignant disease and 
genetic effects, must be considered to have potentially deleterious 
effects on man. The linear extrapolation of carcinogenesis and 
genetic injury from higher levels to the zero dose - zero response 
point seems to offer the most reasonable quantitative approach to 
the problem. This is the approach used by most standard setting 
bodies. There is some evidence that this model may overestimate 
the damage from X- and Gamma rays, but there is no evidence that 
it overestimates the damage from particles having high linear 
transfer of energy (LET) such as alpha particles and neutrons. 
There are suggestions that it may underestimate such injury. 

Even though I am convinced that "all radiation is harmful" 
to man, I am not certain that this justifies the banning of nucle- 
ar power or any other beneficial use of radiation. At low levels 
the amount of harm is very small and has little significance to 
individuals. Since our society, as a whole, is willing to accept 
the well known risks associated with automobile driving, with 
dangerous sports, with tobacco smoking, with alcohol consumption, 
and with fire hazards in many types of buildings, it is my 
feeling that our society would be willing to accept a small risk 
from nuclear power. The main reason, I think, for public alarm 
over the hazards of nuclear power is that for most, it is still 
a new and poorly defined hazard. New and poorly defined hazards 
are always much more frightening than familiar hazards - ones 
that we have learned to live with. 


Addition to the Testimony of Dr. Edward A. Martell, Unresolved Health Effects 

Of Internal Alpha Emitters 

Before the acceptability of nuclear energy can be judged, there must be an 
adequate evaluation of the associated health risks. Unfortunately neither the 
AEC nor our health agencies have addressed themselves adequately to the assess- 
ment of the chronic health effects of Internal alpha emitters in man. It is well 
established that alpha emitters are effective agents of cell mutation and cancer. 
The critical, unresolved questions are: to what extent are internal alpha emitters 
contributing to the general incidence of each of the serious chronic health effects 
in man: cancer, heart disease and stroke, genetic effects, sclerotic disorders, 
etc . 

The possibility that insoluble alpha emitting particles may play a major role 
in the general incidence of human cancer is supported by the growing evidence 
that lung cancer in cigarette smokers is induced by alpha radiation. The measured 
concentrations of radioactive lead-210 and poloniuTn-210 at the bronchial tumor 
sites of cigarette smokers range up to thousands of times that found in non-smokers 
(1) . Although only fractions of a picocurie of polonium-210 alpha activity are 
involved, the local alpha radiation intensity at the cellular level ranges from 
thousands to hundreds of thousands times natural levels. In a recent article (2) 
I proposed that the induction of cancer by alpha radiation is likely to involve a 
multiple mutation process and, thus, insoluble alpha emitting particles of moderate 
activity (i.e., "warm" particles) which persist in tissue can be very effective 
agents of cancer. A T^.ultiple nutation process of alpha radiation induced cancer 
is consistent with both the age distribution of cancer and the observed higher 
incidence of cancer per rad for spaced alpha irradiation exposure (2). It is 
disturbing to note that for cancer i-duction by a multiple r-utation process it 
is highly unconservative to extrapolate linearly to low doses. On this basis, 
exceedingly sniall organ burdens of insoluble alpha emitters would be equated with 
significant tumor risks. If insoluble alpha emitting saoke particles prove to be 
the agent of cancer in smokers, then insoluble alpha emitting from other sources 
including fallout plutonium are likely to be contributing significantly to the 
rising general incidence of cancer in non-smokers. 

iSponsored by the National Science Foundation. 


The magnitude of the contribution of internal alpha emitters to spontaneous 
mutations and genetic effects in man is also a serious neglected question. The 
Subcommittee on Genetic Effects of the National Academy of Sciences Advisory 
Committee on the Biological Effects of Ionizing Radiations concluded (3) that the 
genetically significant exposure of man from nuclear pollutants is now very small 
relative to that from natural background radiation which, in turn, is considered 
to be of minor inportance comp;^red to non-radioactive mutagens. This assessment 
is based on X-ray effects on mice and on other considerations which render these 
conclusions applicable only to the X-ray and gar,.?ia ray ccniponr-nt of human genetic 
effects. Recent studies have shov-n higher concentrations of plutoniura in human 
gonads and lymph nodes than in other soft tissue organs. And there is published 
evidence that both plutoniura and polonium-210 in the testes are distributed in a 
manner which gives a much higher dose to the sperm than to the testes as a whole. 
Thus there is basis for suggesting that internal alpha emitters rather than un- 
identified non-radioactive mutagens may F.ake the major contribution to the current 
spont«r.eoiis r utaticn rate in iran. 

The acceptability of nuclear er.ergy will remain in doubt until we resolve 
these disturbing questions regarding cancer risks and genetic effects of internal 
alpha emitters. The microdistribution of alpha emitters in the gonads and at the 
iiiiportant tuinor sites can be determined with experimental techniques now available. 
Studies of the alpha activity burden and distribution at the turaor sites in high 
risk exposure groups also would provide a reasonable test of the multiple mutation 
hypothesis and its serioijs i'r.plications . Such studies nust be carried out before 
we are con uitted to further proliferation of nuclear energy. To co olhf ri,'ise would 
be reckless ard irresponsible and would pose a serious threat to the health and well- 
being of future gontf ations. 

To rf'.ody the situat ion, the following courses of action are recommended: 

1. Reconvene the NAS-BEIR Conaittee for tlie purpose of considering: 

(a) the "wann particle" hypothesis of aloha radiation induced cancer 

(b) the evidence for a multiple mutation process of csncer induction 
and its inplications 

(c) the microdistribution of alpha ei^itters and othtrr radioisotopes in 
the gonads and their genetic effects. 

2. Establish a program of radiation induced cancer research under the 
auspices of the Departricnt of Health, Education and Welfare. 


3. Organize a high priority research effort to assess the mlcrodistribution 
of internal alpha emitters at the tumor sites of high cancer risk groups, 
to determine the burden and distribution of radioisotopes in human gonads, 
and to evaluate the conceiitration of radioisotopes on effluent particles 
of respirable size for selected industrial and environmental sources. 

4. Defer further proliferation of nuclear energy until there is an adequate 
appreciation of the chronic health effects of radiation, with special 
emphasis on internal alpha emitters. 

References : 

1. Radford, E.P. and E.A. Martell, "Polonium-210 : lead-210 ratios as an 
index of residence times of insoluble particles from cigarette 
smoke in bronchial epithelium". Proceedi ngs of t he Fourt h In ternational 
S^-TTiposium on Inhaled Parti cles and Vapo urs, Edinburgh, 22-26 September 
1975, Perga:,on Press Ltd. 

2. Martell, E.A., "Tobacco radioactivity and cancer in smokers", American 
Scie^irt^ist, 63, 404-412, July-August 1975. 

3. National Academy of Sciences Advisory Committee on the Biological Effects 
of Ionizing Radiations, "The effects on populations of exposure to low 
levels of ionizing radiation", (BEIR Report), NAS-NRC, November 1972, 
Washington, D.C. 20006 


Submitted to the Record by Dr. Rosalie Bertell, Recommendations Made to the 
Environmental Study Conference 

'.Hiereis, In thp past ^-'e h=jve frilled to recofnlze the fact that ion- 
jzinp radiation has different bioloplcal effects relative to dose, 
dose rate, and to the susceptibility of the person exposed, and 
v.'hereas this error has caused serious under-estlmation of the long 
tern effects of radiation pollution of the environment, I propose: 







^Tnereas our present methods of collecting health related data are 
inadequate for protecting either employees or the general public 
against long term chronic or lethal effects of environmental 
pollution, I propose: 










V/here^s the use of ^idvertisinp techniques on the part of the nuclear 
industry and government agencies in the promotion of the nuclear 
industry has confused scientific questions and misled the public, 
I propose that: 



'/hereas all of the above problems seem to stem from our basic orien- 
tation tovard economic gain rather than human progress, tov'ard 
v/ealth and pov/er instead of health and vrell-being, I propose that 
Congress : 








University of Pittsburgh 

fACULTY OF Afo;, AM) .cuNci s May 10, 1976 

DcpaitmenI of Physics 

Congressman Richard L. Ottinger 
Environmental Study Conference 
2456 Rayburn House Office Building 
Washington, DC 20515 

Dear Congressman Ottinger: 

I am very sorry that I was unable to be present at your conference 
on May 4. I was down with a virus and had a high fever; in fact I am 
still not very well recovered from it. I hope the message I called in 
was delivered and there were no bad consequences from my absence. 

Since I was unable to attend, there is one point I would like to 
make in writing here. As far as I am concerned, it is the most important 
point about the'whole conference. That is — your group of "experts" were 
mostly not experts; in other words, if you are seeking authoritative 
information, you had the wrong group. 

We are fortunate in having prestigeous groups available to study 
biological effects of radiation -- ICRP, NCRP, the UN committee, the National 
Academy of Sciences Committee, the British Medical Research Council, etc. 
The true experts sit on these committees. All of these committees agree 
rather well on the issues; from your viewpoint, the differences among them 
are negligible. 

But your group of "experts" at the May 4 meeting were not representative 
of these groups. The NCRP has about 70 members, and including past members 
they form a group of about 150 who are the true experts. Yet only about 
1/4 of the members of your panel are among these 150. Effects of low-level 
radiation are estimated principally from animal studies but there is not a 
single member of your panel who has ever done such animal studies. 

I therefore believe that any information obtained from that 
conference is highly suspicious. If you really want information, you 
should call in the experts. 

Sincerely yours , 

Bernard L. Cohen 

BLC:bem _ 

PITTSBURGH, PA T5?60 -135-